Comment Letters

  • September 22, 2014
    Re: Proposal to Disclose Consumer Complaint Narratives Docket No. CFPB–2014–0016 Dear Ms. Jackson: The Consumer Bankers Association (“CBA”)1 appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) notice of proposed policy statement concerning disclosure of consumer complaint narratives through the Bureau’s complaint portal (“Proposal”). While CBA...
  • September 19, 2014
    Before the FEDERAL COMMUNICATIONS COMMISSION PETITION FOR DECLARATORY RULING OF THE CONSUMER BANKERS ASSOCIATION EXECUTIVE SUMMARY The Consumer Bankers Association (“CBA”) respectfully asks the Federal Communications Commission (“FCC” or “Commission”) to declare that “called party,” for purposes of the Telephone Consumer Protection Act’s (“TCPA”) restrictions on certain automated calls, including...
  • September 10, 2014
    Re: Mobile Financial Services Request for Information – Docket No. CFPB-2014-0012 Dear Ms. Jackson: The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the notice issued by the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) asking for input on how mobile banking is helping consumers utilize products, manage finances, and achieve financial goals. CBA...
  • September 8, 2014
    An Open letter to the U.S. Congress from the Consumer Credit Industry: Motor Vehicle Finance Creates Opportunity and Drives Economic Growth Over the past few weeks, some in the media have raised alarms comparing motor vehicle finance with the residential mortgage bubble nearly seven years ago. The comparison was quickly and persuasively discredited by the more sophisticated financial press1 and...
  • August 22, 2014
    RE: Information Collection – Debt Collection Survey from the Consumer Credit Panel, OMB Control Number 3170-XXXX [Docket No: CFPB-2014-0017] Dear Mr. Vasan: The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond to the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) second request for comments on its proposed “plans to conduct a mail survey of consumers to...
  • August 20, 2014
    Dear Director Cordray, Recently, the Consumer Financial Protection Bureau's (CFPB) Private Education Loan Ombudsman sent letters to financial institutions that have contractual relationships with colleges and universities – relationships unrelated to the student loan or financial aid portfolios – calling for public disclosure of their agreements. The Ombudsman’s letter stated the institutions’...
  • August 20, 2014
    By electronic delivery Ms. Lynn Mahaffie Acting Assistant Secretary for Postsecondary Education Department of Education Dear Ms. Mahaffie, Earlier this year, the Department of Education considered in its negotiated rulemaking process proposals related to ways educational institutions manage Title IV, Higher Education Act program funds. The American Bankers Association (ABA) and the Consumer...
  • August 5, 2014
    John B. Morris Associate Administrator and Director of Internet Policy Department of Commerce National Telecommunications and Information Administration Dear Mr. Morris: The Consumer Bankers Association (“CBA”) and the American Bankers Association (“ABA”) appreciates the opportunity to comment on the notice issued by the Department of Commerce’s National Telecommunications and Information...
  • August 1, 2014
    Re: Support for the Cybersecurity Information Sharing Act of 2014 Dear Majority Leader Reid and Minority Leader McConnell: The undersigned financial services organizations are writing in strong support of S. 2588, the “Cybersecurity Information Sharing Act of 2014,” or CISA, favorably reported out of the Senate Select Committee on Intelligence on July 10th by a bipartisan 12-3 vote. CISA will...
  • July 21, 2014
    Ladies and Gentlemen: On July 16, Director Cordray announced that the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) was considering adopting a policy to expand the manner in which it discloses certain complaint data it receives regarding consumer financial products and services via its web-based, public-facing database (the “Consumer Complaint Database”). Specifically, the proposed...

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