Comment Letters

  • April 10, 2013
    Dear Director Cordray: The Consumer Bankers Association, the American Bankers Association, The Financial Services Roundtable3 and its Housing Policy Council4 (collectively, the “Associations”) respectfully submit to the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) this letter on complying with the Bureau’s new mortgage rules. In order to ensure the new rules achievope their intended...
  • April 10, 2013
    To read the full Comment Letter, download the PDF .
  • April 10, 2013
    To read the full Comment Letter, download the PDF .
  • April 4, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA)i appreciates the opportunity to submit comments in response to the Consumer Financial Protection Bureau’s (CFPB’s or Bureau’s) request for information (RFI) from the public to determine options that would increase the availability of affordable payment plans for borrowers with existing private student loans. We understand the Bureau will...
  • March 27, 2013
    Dear Sirs: The Consumer Bankers Association (CBA) appreciates your past willingness to discuss how to assist private student loan borrowers experiencing difficulty repaying their loans. We believe it is important to work to address the challenges we are seeing in today’s economic environment. Private student loans only account for approximately 7 percent of today’s student loan originations,...
  • 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...

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