Comment Letters
April 11, 2022Director Chopra, This letter is submitted by the Consumer Bankers Association (“CBA”) in response to the Consumer Financial Protection Bureau’s (“Bureau”) Request for Information (the “Request”) regarding fees imposed by providers of consumer financial products or services. CBA has several concerns with the Request’s portrayal of consumer finance markets. First, fee amounts and fee disclosures...
March 30, 2022Dear Chairman Perlmutter and Ranking Member Luetkemeyer: The Consumer Bankers Association (CBA) submits this letter for the record for the hearing entitled “The End of Overdraft Fees? Examining the Movement to Eliminate the Fees Costing Consumers Billions.” Overdraft is a safe and affordable form of immediate short-term liquidity used by millions of consumers to ensure they can continue to...
March 25, 2022Dear Director Chopra: The Consumer Bankers Association (CBA) 1 appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB or Bureau) request for comments on Buy-Now-Pay-Later (BNPL) in the United States. Not only are BNPL products very popular with consumers, but they can also play a positive role in consumers’ lives by making a purchase possible and extending...
March 17, 2022TO THE MEMBERS OF THE U.S. HOUSE OF REPRESENTATIVES: We, the undersigned associations, urge you to oppose H.R. 963, the “Forced Arbitration Injustice Repeal (FAIR) Act,” which would effectively ban arbitration provisions in private contracts. Federal law has protected arbitration as a means of resolving disputes between businesses, consumers, and employees since 1925. Should it become law, this...
March 8, 2022Dear Chair Brown and Ranking Member Toomey: The undersigned organizations appreciate the opportunity to provide comments to the Committee on Banking, Housing, and Urban Affairs in advance of the March 8th hearing titled “Examining Mandatory Arbitration in Financial Service Products.” Arbitration is a fair, effective, and less expensive means of resolving disputes compared to going to court. It...
March 4, 2022Dear Chairman Brown and Ranking Member Toomey: I write on behalf of the Consumer Bankers Association (CBA) regarding the hearing entitled “Examining Mandatory Arbitration in Financial Service Products.” CBA is the voice of the retail banking industry whose products and services provide access to credit for consumers and small businesses. Our members operate in all 50 states, serve more than 150...
February 18, 2022Jonathan Kanter Assistant Attorney General for the Antitrust Division U.S. Department of Justice 950 Pennsylvania Avenue, N.W., Washington, D.C. 20530. Dear Assistant Attorney General Kanter: The Consumer Bankers Association (CBA) 1 appreciates the opportunity to comment on the Department of Justice’s Antitrust Division’s (DOJ) request for comments as to whether and how the DOJ should revise the...
February 9, 2022Director Chopra: The Consumer Bankers Association (CBA) writes to urge the Consumer Financial Protection Bureau (Bureau) to supervise nonbank small business lenders. While banks are typically the first place that small businesses consider when seeking a loan, the landscape for business lending has changed substantially in recent years, with alternative banking options offered by financial...
January 24, 2022Dear Director Chopra, The American Bankers Association, 1 Consumer Bankers Association, 2 Credit Union National Association, 3 National Association of Federally-Insured Credit Unions, 4 and National Bankers Association 5 write in response to the two overdraft research reports that the Consumer Financial Protection Bureau issued on December 1, 2021. 6 As expected, these reports have stimulated...
Joint Trades Response to CFPB Fees RFI CFPB-2022-0003