Comment Letters
November 22, 2013The American Bankers Association, the Consumer Bankers Association, and the Mortgage Bankers Association are pleased to comment on the Consumer Financial Protection Bureau’s (“CFPB” or the “Bureau”) October 23, 2013 Interim Final Rule that amends certain mortgage servicing-related provisions in Regulation X and Regulation Z as well as the corresponding Commentary to these rules (collectively, the...
November 20, 2013Dear Chairman Goodlatte, We commend you for your work on the Amendment in the Nature of a Substitute to HR 3309, the “Innovation Act of 2013,” to address the continued onslaught of frivolous patent litigation brought by non-practicing entities (“NPEs”). Following the successful implementation of the America Invents Act of 2011 (“AIA”), the Innovation Act holds the promise to further constrain the...
November 14, 2013November 14, 2013 Mr. Rohit Chopra Student Loan Ombudsman Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Dear Mr. Chopra: The recent consumer advisory and sample letter regarding special payment instructions for private education loans have raised questions and concerns in the related servicing and lender communities. The Consumer Bankers Association (CBA) shares...
October 30, 2013Dear Sirs or Madams: The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the credit risk retention proposal issued on August 28, 2013 by the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, and the Securities and Exchange Commission (the “...
October 30, 2013Dear Sir or Madam: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments in response to the proposed rule that would determine which loans would be defined as a qualified mortgage (QM) for single family mortgages insured and guaranteed by the Department of Housing and Urban Development (HUD). Under the Dodd–Frank Wall Street Reform and Consumer Protection Act, HUD...
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...
Joint Comment Letter on Biggert-Waters Proposed Rule regarding Escrow Requirements for Flood Insurance