Comment Letters

  • March 25, 2013
    Dear Ms. Dupre: The Consumer Bankers Association (CBA)1 appreciates the opportunity to submit comments in response to the Federal Financial Institutions Examination Council’s (FFIEC’s), proposed guidance titled “Social Media: Consumer Compliance Risk Management Guidance” (Guidance). Once finalized, financial institutions and others will be expected to use the Guidance in their efforts to ensure...
  • March 18, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA)1 and the American Bankers Association (ABA)2 (collectively “the Associations”) submit this letter in response to the Consumer Financial Protection Bureau’s (Bureau) Request for Information Regarding Financial Products Marketed to Students Enrolled in Institutions of Higher Education (RFI). The Associations appreciate the opportunity to...
  • March 7, 2013
    Dear Director: On December 31, 2012 the Department of Education published a notice of information collection activities associated with Preferred Lender Arrangements (Part 601). The regulations require covered educational institutions to provide a variety of new loan disclosures on private student loans. In the notice, the Department noted it is submitting the Private Education Loan Applicant...
  • February 27, 2013
    Dear Secretary Duncan, The Consumer Bankers Association (CBA) and its members are strong supporters of higher education and recognize the tremendous value a degree can provide. While a small part of the overall market, our member banks in the private student loan business stand ready to assist students and families address their higher education financing needs. As President Obama has highlighted...
  • February 25, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA)1 appreciates the opportunity to submit comments in response to the proposal issued in conjunction with the January 10, 2013 ability-to-repay/qualified mortgage (QM) final rules (the Proposal). The Proposal includes a request for comment on additional clarifications regarding the inclusion of loan originator compensation within the 3 percent...
  • February 19, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA)1 appreciates the opportunity to submit comments in response to the Consumer Financial Protection Bureau’s (CFPB’s or Bureau’s) request for information (RFI) to study the effect of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) on the credit card market. The CFPB states it will use the information...
  • February 15, 2013
    Dear Ms. Jackson: The Consumer Bankers Association, the American Bankers Association, and the American Bankers Insurance Association (collectively, the “Associations”) appreciate the opportunity to submit comments on the Proposed Policy (“Proposal”) to exempt individual companies, on a case-by-case basis, from current federal disclosure requirements in order to test “trial disclosures.” The...
  • January 15, 2013
    Dear Ms. Jackson: The Clearing House Association L.L.C., the American Bankers Association, the Consumer Bankers Association, The Financial Services Roundtable, the Independent Community Bankers of America, NACHA – The Electronic Payments Association, and the National Association of Federal Credit Unions (collectively, the “Associations”) respectfully submit to the Bureau of Consumer Financial...
  • January 7, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments in connection with the proposal to amend the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Card Act) rules, along with proposed revisions to the applicable official interpretations. Currently, these rules require credit card issuers to consider a consumer’s independent...

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