Preemption

CBA supports strong, uniform federal standards for federally chartered institutions. Federal preemption is a legal doctrine that holds a federal law governs all claims that fall within it and offers a vital safeguard against unwarranted and inconsistent state interferences with the national economy. In the banking industry, preservation of uniform federal standards has benefited consumers of financial products by making a wider range of banking products and services available to more consumers and, overall, lowering the costs of credit and other banking products and services. In turn, the banking system benefits from greater economies of scale and improved risk management.
  • January 17, 2014
    Deposit Advance Products We learned this week Regions Financial, U.S. Bank, Wells Fargo and Fifth Third have decided to phase out their Deposit Advance Products. This development was a point of discussion during my meeting with CFPB Director Cordray on January 16, 2014. The vast majority of consumers using deposit advance products do so responsibly under transparent and fully disclosed terms...
  • December 6, 2013
    Ladies 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 1, 2013
    Senators Question CFPB’s Indirect Auto Lending Bulletin On October 30, 2013, Sens. Rob Portman (R-OH) and Jeanne Shaheen (D-NH) lead a bipartisan group of 22 Senators in a letter to CFPB Director Cordray regarding the Bureau’s March 21, 2013, bulletin on indirect auto lending. The letter echoes concerns raised this summer by members of the House of Representatives. The Senators call for...
  • September 18, 2013
    Dear Chairmen and Ranking Members: The Consumer Bankers Association (CBA), the only trade association exclusively dedicated to the retail banking industry, would like to thank the Subcommittee for holding this hearing to discuss progress and challenges with implementation of the Biggert-Waters Flood Insurance Act of 2012 (Biggert-Waters). On July 6, 2012, President Obama signed Biggert-Waters,...
  • September 6, 2013
    CFPB Names Steven Antonakes Deputy Director On Wednesday, September 4, 2013, the CFPB officially named Steven Antonakes its deputy director. He has served as the Bureau’s acting deputy director since January. CBA President and CEO, Richard Hunt, issued a statement congratulating Antonakes, adding, “CBA looks forward to continuing to work with the CFPB and him in the coming months and years.” CFPB...
  • May 30, 2013
    Dear Mr. Feldman: This comment letter is submitted by the Consumer Bankers Association, The Financial Services Roundtable , and The Clearing House (collectively the “Associations”) in response to proposed supervisory guidance (“Proposal”) regarding deposit advance products, which was published in the Federal Register on April 30, 2013, by the Federal Deposit Insurance Corporation (“FDIC” or “...
  • May 17, 2013
    Gentlemen: In February of this year, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Board of Governors of the Federal Reserve System (the “Agencies”), in conjunction with the Bureau of Consumer Financial Protection, proposed significant revisions to the Consolidated Reports of Condition and Income (“Call Report”), all but one of which would be...
  • April 26, 2013
    CFPB Director Cordray Testifies Before Senate Banking Committee On Tuesday, April 23, 2013, CFPB Director Richard Cordray testified before the Senate Banking Committee on the CFPB’s Semi-Annual Report to Congress . The Committee discussed a number of pressing issues with Director Cordray, most notably, CFPB collection of “big data,” the consumer complaint database, indirect auto lending, student...

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