Comment Letters

  • August 12, 2021
    Dear Ms. Misback: The undersigned trade associations, which represent virtually all the Nation’s regulated financial institutions, write to request that the Board of Governors of the Federal Reserve System (“Board”) withdraw the recent Federal Reserve proposal (“Proposal”) to amend Regulation II (12 C.F.R. Part 235),1 unless it is revised materially in the manner recommended herein. During this...
  • August 9, 2021
    To Whom It May Concern: The Consumer Bankers Association (CBA) is pleased to provide comments in response to your Request for Input (RFI) on Eligibility Requirements for Single Family MBS Issuers. CBA is the only national trade association focused exclusively on retail banking. Established in 1919, the association is now a leading voice in the banking industry and Washington, DC, representing...
  • July 30, 2021
    Ladies and Gentlemen: On behalf of this country’s banks, of all sizes and structures, the undersigned bank trade associations respectfully request that the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the “Agencies”) provide an additional 30 days for interested stakeholders to submit...
  • July 27, 2021
    Dear Chair Warren and Ranking Member Kennedy: On behalf of the Education Funding Committee of the Consumer Bankers Association (CBA), I am writing to share our views for the July 27, 2021 hearing entitled “Protecting Student Loan Borrowers and the Economy in Upcoming Transitions.” We appreciate the Subcommittee’s continued interest in student loan debt and share your concerns about the negative...
  • July 23, 2021
    Dear Chairman Brown and Ranking Member Toomey: The undersigned trade associations, representing depository institutions that serve millions of American consumers, are pleased to share our views on pending legislative measures that propose to limit the fees and interest charged on consumer loans, such as bills that would impose a national “fee and interest rate” cap of 36%. Small dollar loans,...
  • July 16, 2021
    Dear Mr. Sheesley, The Bank Policy Institute and the Consumers Bankers Association (together, the "Associations") appreciate the opportunity to comment on the request for information issued by the Federal Deposit Insurance Corporation seeking input regarding insured depository institutions' current and potential activities related to digital assets. Banks have traditionally been at the forefront...
  • July 15, 2021
    The Consumer Bankers Association (“CBA”) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (“Bureau” or “CFPB”) Advanced Notice of Proposed Rulemaking (ANPR) concerning Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Section 1033”). In 2017, the Bureau released “Consumer Protection Principles: Consumer-Authorized Financial Data...
  • July 12, 2021
    Ann Misback Secretary Board of Governors of the Federal Reserve 20th Street and Constitution Ave Washington, DC 20551 Re: Proposed Guidelines for Evaluating Account and Services Requests (Docket No. OP-1747), 86 FR 25865 (May 11, 2021) Dear Ms. Misback: The undersigned group of trade associations representing financial institutions of all charter types and sizes appreciates the opportunity to...
  • July 1, 2021
    Ladies and Gentleman: The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond and comment on the Request for Information (“RFI”) issued by the Board of Governors of the Federal Reserve System, Bureau of Consumer Financial Protection, Federal Deposit Insurance Corporation, National Credit Union Administration and the Office of the Comptroller of the Currency (collectively “...
  • June 28, 2021
    D ear C h air W a t e rs and Ra n ki n g M e m b er M c H enr y : On b eha l f o f t h e C o n s u m er Bankers Ass o ciat i o n ( CB A ), I am w riti n g to sh a re o u r v i e w s b e f o r e the heari n g entitled “ A Bi a s ed, B r o k en Syst e m : Ex a m i n i n g P r o p o s a ls to O v erh au l Cred i t Re p o r ti n g t o A ch i e v e Eq u i t y .” C B A is the v o i c e o f t h e r e...

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