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.
  • April 17, 2013
    Dear Senator Shelby: The undersigned organizations wish to express our support for S. 737, the “Basel III Impact Study Act”, particularly the provisions that would require the Federal banking agencies to perform a Quantitative Impact Study (QIS) of the proposed Basel III framework. We were also pleased to see similar legislation, H.R. 1221, introduced in the House of Representatives by...
  • April 16, 2013
    Statement of Charles G. Kim On Behalf of the Consumer Bankers Association Before the House of Representatives Committee on Financial Services Financial Institutions and Consumer Credit Subcommittee Regarding Regulatory Relief April 16, 2013 Statement of Charles G. Kim Before the Committee on Financial Services Financial Institutions and Consumer Credit Subcommittee April 16, 2013 Madam Chairman,...
  • March 25, 2013
    Dear Ms. Dupre: The Consumer Bankers Association (CBA)1 appreciates the opportunity to submit comments in response to the Federal Financial Institutions Examination Council’s (FFIEC’s), proposed guidance titled “Social Media: Consumer Compliance Risk Management Guidance” (Guidance). Once finalized, financial institutions and others will be expected to use the Guidance in their efforts to ensure...
  • January 7, 2013
    Dear Ms. Jackson: The Consumer Bankers Association (CBA) appreciates the opportunity to submit comments in connection with the proposal to amend the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Card Act) rules, along with proposed revisions to the applicable official interpretations. Currently, these rules require credit card issuers to consider a consumer’s independent...

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