Comment Letters
December 16, 2013Amici respectfully submit that their motion for leave to participate in oral argument should be granted. Appellees’ arguments in opposition are meritless. 1. Appellees (“the merchants”) do not dispute that amici’s members have a direct, unique stake in this litigation. Opp. 1-2. Nor could the merchants dispute the point. Amici’s members are the very parties regulated by Regulation II. The...
December 13, 2013Dear Mr. Sedgewick: The Financial Services Sector Coordinating Council1 (FSSCC) appreciates the opportunity to provide comments in response to the National Institute of Standards and Technology Request for Comments on the Preliminary Cybersecurity Framework (“Framework”). FSSCC submits this response to demonstrate the deep commitment of the financial services sector to the public/private...
December 6, 2013Ladies and Gentlemen: The American Bankers Association, its insurance subsidiary, the American Bankers Insurance Association, and the Consumer Bankers Association (the Associations) appreciate the opportunity to comment on the proposal by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Farm Credit...
November 22, 2013The American Bankers Association, the Consumer Bankers Association, and the Mortgage Bankers Association are pleased to comment on the Consumer Financial Protection Bureau’s (“CFPB” or the “Bureau”) October 23, 2013 Interim Final Rule that amends certain mortgage servicing-related provisions in Regulation X and Regulation Z as well as the corresponding Commentary to these rules (collectively, the...
November 20, 2013Dear Chairman Goodlatte, We commend you for your work on the Amendment in the Nature of a Substitute to HR 3309, the “Innovation Act of 2013,” to address the continued onslaught of frivolous patent litigation brought by non-practicing entities (“NPEs”). Following the successful implementation of the America Invents Act of 2011 (“AIA”), the Innovation Act holds the promise to further constrain the...
November 14, 2013November 14, 2013 Mr. Rohit Chopra Student Loan Ombudsman Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Dear Mr. Chopra: The recent consumer advisory and sample letter regarding special payment instructions for private education loans have raised questions and concerns in the related servicing and lender communities. The Consumer Bankers Association (CBA) shares...
October 30, 2013Dear Sirs or Madams: The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the credit risk retention proposal issued on August 28, 2013 by the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, and the Securities and Exchange Commission (the “...
October 30, 2013Dear Sir or Madam: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments in response to the proposed rule that would determine which loans would be defined as a qualified mortgage (QM) for single family mortgages insured and guaranteed by the Department of Housing and Urban Development (HUD). Under the Dodd–Frank Wall Street Reform and Consumer Protection Act, HUD...
October 30, 2013Dear Commissioner Galante: The undersigned Associations are grateful for the important work of the Department of Housing and Urban Development (HUD) in developing a proposed rule to define a Qualified Mortgage (QM) for purposes of the Federal Housing Administration (FHA) Insured and Guaranteed Single Family Mortgage Program. Absent such a definition, we believe many consumers would be needlessly...
CBA Joint Comment Letter to FCC in Support of the Revised TCPA Exemption Proposal from the Cargo Airline Association