Comment Letters
October 30, 2013Dear Commissioner Galante: The undersigned Associations are grateful for the important work of the Department of Housing and Urban Development (HUD) in developing a proposed rule to define a Qualified Mortgage (QM) for purposes of the Federal Housing Administration (FHA) Insured and Guaranteed Single Family Mortgage Program. Absent such a definition, we believe many consumers would be needlessly...
September 20, 2013Dear Chairman Baucus and Ranking Member Hatch: As your committee begins its historic effort to address tax reform, the Consumer Bankers Association (CBA) wishes to take this opportunity to speak on behalf of its member banks and their efforts to serve low-income consumers. Two very important federal programs drive private investment for affordable housing and job creation in lowincome areas: Low...
September 18, 2013Dear Chairmen and Ranking Members: The Consumer Bankers Association (CBA), the only trade association exclusively dedicated to the retail banking industry, would like to thank the Subcommittee for holding this hearing to discuss progress and challenges with implementation of the Biggert-Waters Flood Insurance Act of 2012 (Biggert-Waters). On July 6, 2012, President Obama signed Biggert-Waters,...
August 28, 2013Dear Ms. Finkel: As the trade associations representing the majority of student loan providers (guaranty agencies, lenders and servicers) in the Federal Family Education Loan Program (FFELP), and having had colleagues act as negotiators during the 2012 negotiated rulemaking sessions for the “Loan Issues” committee, we write to express our appreciation for the opportunity to contribute to this...
August 8, 2013August 8, 2013 The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Request for Guidance and Clarity on the Ability-to-Repay/Qualified Mortgage Rules Dear Director I very much appreciate the recent time and attention you personally provided to the Consumer Bankers Association (CSA) in addressing certain issues of concerns we have...
August 6, 2013Ladies and Gentlemen: The Financial Services Roundtable, the Consumer Bankers Association, and the American Bankers Association appreciate the opportunity to comment on the request by the Consumer Financial Protection Bureau (the “Bureau”) for information concerning a proposed survey of “consumer awareness of dispute resolution provisions in their agreements with credit card providers,” and “[w]...
August 5, 2013Dear Director Cordray, The Consumer Bankers Association (CBA), the Education Finance Council (EFC), the National Council of Higher Education Resources (NCHER) and the Student Loan Servicing Alliance (SLSA) are writing to urge the Consumer Financial Protection Bureau (the “Bureau”) to immediately provide private student loan providers with a 30-day compliance grace period for lenders and servicers...
August 2, 2013Dear Sir or Madam: The undersigned trade associations (the Associations) appreciate the opportunity to offer our views on the advance notice of proposed rulemaking (ANPR) recently issued by the Department of Defense (Department). The ANPR seeks comment on whether the Department should consider revising existing protections under the Military Lending Act which apply to consumer credit extended to...
July 29, 2013Dear Chairman Rockefeller and Ranking Member Thune: The undersigned organizations, representing the financial services industry, are writing in support of S. 1353, the Cybersecurity Act of 2013, as introduced, and to thank you for your leadership in forging a bipartisan bill. S. 1353 would improve the cybersecurity of our nation in several ways. In particular, it encourages the private and public...
CBA Comment Letter to HUD regarding QM Definitions