Comment Letters

  • April 28, 2020
    April 28, 2020 The Honorable Jovita Carranza Administrator U.S. Small Business Administration 409 3rd Street, S.W. Washington, D.C. 20460 Dear Administrator Carranza: As trade associations representing banks and credit union members across the country actively participating in the Small Business Administration’s Paycheck Protection Program (PPP), we are reaching out to share our continuing...
  • April 23, 2020
    April 23, 2020 William Manger Associate Administrator U.S. Small Business Administration 409 3rd Street, SW Washington, D.C. 20416 Michael Faulkender Assistant Secretary for Economic Policy United States Department of the Treasury Treasury Building 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 Re: Implementing the Paycheck Protection Program Dear Associate Administrator Manger and Assistant...
  • April 23, 2020
    The Honorable Steven T. Mnuchin Secretary U.S Department of Treasury 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 The Honorable Jovita Carranza Administrator Small Business Administration 409 Third Street, SW Washington, D.C. 20416 Dear Secretary Mnuchin and Administrator Carranza I write to you regarding the “Paycheck Protection Program and Health Care Enhancement Act’’ that was recently...
  • April 21, 2020
    Dear Mr. Feldman: The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the Federal Deposit Insurance Corporation’s (“FDIC’s”) request for information regarding sign and advertising requirements. CBA applauds the FDIC’s initiative to seek input about potentially modernizing sign and advertising rules to reflect the evolution of deposit-taking channels since the rules...
  • April 20, 2020
    Ms. Dortch: The Consumer Bankers Association (CBA) writes regarding the Petition for Expedited Declaratory Rule, Clarification, or Waiver filed by CBA, the American Bankers Association, and other associations March 30, 2020 (Petition). CBA strongly urges the Federal Communications Commission (FCC) to act without delay to issue an interim declaratory ruling stating calls and text messages placed...
  • April 17, 2020
    Dear Chair Powell: The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the Federal Reserve’s Main Street Lending Program (“Main Street”). CBA applauds the Federal Reserve for swiftly acting to aid America’s small- and mid-sized businesses as we endure the uncertainties presented by the COVID-19 crisis. CBA has reviewed the details of the Main Street Lending Program...
  • April 15, 2020
    April 15, 2020 William Manger Associate Administrator U.S. Small Business Administration 409 3rd Street, SW Washington, D.C. 20416 Michael Faulkender Assistant Secretary for Economic Policy United States Department of the Treasury Treasury Building 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 Re: Implementing the Paycheck Protection Program Dear Associate Administrator Manger and Assistant...
  • April 8, 2020
    To Whom It May Concern: The Consumer Bankers Association (CBA) [1] is pleased to submit these comments to the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) (together, the “Issuing Agencies”) on behalf of its members in response to the Notice of Proposed Rulemaking (NPR) entitled “Community Reinvestment Act Regulations.” [2] Buckley LLP [3] helped...
  • March 30, 2020
    The American Bankers Association (ABA), American Financial Services Association (AFSA), Consumer Bankers Association (CBA), Credit Union National Association (CUNA), Independent Community Bankers of America (ICBA), Mortgage Bankers Association (MBA), and National Association of Federally-Insured Credit Unions (NAFCU) (collectively, the Associations) request an expedited declaratory ruling,...
  • March 28, 2020
    March 28, 2020 Administrator Jovita Carranza Small Business Administration 409 Third Street, SW Washington, D.C. RE: COVID 19 - Emergency Small Business Lending Measures Dear Administrator Carranza: America’s small businesses, and the millions of men and women who work at them, are the foundations of communities across the country. These businesses and their employees now face immediate economic...

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