Comment Letters

  • 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...
  • May 17, 2013
    Gentlemen: In February of this year, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Board of Governors of the Federal Reserve System (the “Agencies”), in conjunction with the Bureau of Consumer Financial Protection, proposed significant revisions to the Consolidated Reports of Condition and Income (“Call Report”), all but one of which would be...
  • May 17, 2013
    Dear sir or madam: The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the proposal by the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Corporation (FDIC) (Collectively, the Agencies) to clarify their Interagency Questions and Answers (Q&A) regarding the Community Reinvestment Act (CRA). CBA...
  • May 6, 2013
    Dear Mr. Kelley: The National Association of Government Guaranteed Lenders (NAGGL) and the Consumer Bankers Association (CBA) (collectively “the Associations”) appreciate the opportunity to comment on the U.S. Small Business Administration (SBA) proposed rule that would amend 13 CFR 121 to modify the rules governing Affiliation as Applied to the Business Loan Programs. The Associations strongly...

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