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- 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 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...
- January 27, 2022In a new op-ed appearing in American Banker, Consumer Bankers Association (CBA) Assistant Vice President & Regulatory Counsel, Brian Fritzsche, examines the rapid growth of “But Now Pay Later” (BNPL) while advocating for policymakers to ensure all families receive the highest level of consumer protections, whether they choose a fintech, Big Tech, or a traditional bank to meet their needs...
- December 14, 2021 - 2:00PMPastOctober 19, 2021 - 2:00PMPastOctober 7, 2021 - 2:00PMPastSeptember 30, 2021 - 2:00PMPastSeptember 30, 2021Dear Chairwoman Khan: The Consumer Bankers Association (“CBA”) appreciates the opportunity to provide our comments in response to the Federal Trade Commission’s (“FTC”) Solicitation for Public Comment on Contract Terms that May Harm Competition (“Solicitation”). In particular, CBA will focus its comments on the reasonable use of non-compete clauses, also known as non-compete agreements...August 16, 2021Dear Chairman Warner and Ranking Member Rubio, In the wake of recent ransomware and other cybersecurity attacks, we appreciate your efforts to improve the resilience of federal agencies and private critical infrastructure, emphasizing the importance of public-private collaboration in this ongoing fight. The financial services sector shares your commitment to cybersecurity and the value in sharing...August 12, 2021Dear 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...