Comment Letters

  • June 24, 2013
    Dear Chairman Johnson and Ranking Member Crapo: The Consumer Bankers Association (CBA) is Washington’s public policy leader for private student lenders and appreciates the opportunity to share some of our views with the Senate Banking Committee for its hearing entitled “Private Student Loans: A Regulatory Perspective.” CBA’s Education Funding Committee represents all the major bank participants...
  • June 21, 2013
    Amici Curiae AMICI’S INTEREST IN THIS CASE Many of Amici’s members, constituent organizations and affiliates (collectively, “Members”) have independently adopted as standard features of their consumer contracts provisions that call for individual arbitration of disputes arising from or relating to those contracts, upon the election of either party. They use arbitration because it is a prompt,...
  • June 17, 2013
    INTEREST OF AMICI CURIAE The American Bankers Association (“ABA”), headquartered in Washington, D.C., is the principal national trade association of the financial services industry. The ABA’s members, located in each of the 50 states, the District of Columbia, and Puerto Rico, include financial institutions of all sizes. ABA members hold a majority of the domestic assets of the banking industry...
  • June 12, 2013
    Dear Chairman Landrieu and Ranking Member Risch: The Consumer Bankers Association (CBA), the only national financial trade group focused exclusively on retail banking and consumer financial services, writes to you in support of S. 289, the “Commercial Real Estate and Economic Development” (CREED) Act of 2013. CBA applauds your leadership on this legislation, which would extend the low-interest...
  • June 4, 2013
    Dear Secretary Donovan and Director Cordray: The undersigned trade associations (the “Associations”) submit this letter to request written guidance that includes a clear safe harbor from liability in areas where multiple federal mortgage standards conflict. The Department of Housing and Urban Development (“HUD”) recently finalized a regulation under the Fair Housing Act that expressly provides...
  • June 3, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments in response to the proposed clarifications to the mortgage rules that were issued in January of this year. These clarifications address certain issues arising under the Ability to Repay (ATR)/Qualified Mortgage (QM) Rule and the Servicing Rule. Specifically, these proposed changes and...
  • May 30, 2013
    Dear Sir or Madam: This comment letter is submitted by the Consumer Bankers Association, The Financial Services Roundtable, and The Clearing House (collectively the “Associations”) in response to proposed supervisory guidance (“Proposal”) regarding deposit advance products, which was published in the Federal Register on April 30, 2013, by the Office of the Comptroller of the Currency (“OCC” or “...
  • May 30, 2013
    Dear Mr. Feldman: This comment letter is submitted by the Consumer Bankers Association, The Financial Services Roundtable , and The Clearing House (collectively the “Associations”) in response to proposed supervisory guidance (“Proposal”) regarding deposit advance products, which was published in the Federal Register on April 30, 2013, by the Federal Deposit Insurance Corporation (“FDIC” or “...
  • May 24, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau’s (CFPB’s or Bureau’s) proposed rule “Defining Larger Participants of the Student Loan Servicing Market,” Docket NO. CFPB-2013-0005. Our comments reflect the view of CBA’s Education Funding Committee. The Committee includes the largest bank lenders of...
  • May 23, 2013
    Dear Ms. Jackson: The undersigned associations (the “Associations”) support the proposal by the Consumer Financial Protection Bureau (the “Bureau”) to delay the June 1st effective date for section 1026.36(i) in the Loan Originator Compensation Requirements rule (the “Final Rule”), which prohibits the financing of single-premium credit insurance offered in connection with residential mortgages...

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