View from CBA April 26, 2013

April 26, 2013

Busy Week for the CFPB

The CFPB has been in a frenzy of activity. In addition to their outstanding financial literacy outreach to consumers this week they:

  • Issued a white paper on payday and deposit advance loans;
  • Issued a statement on deposit advance product announcements by banking regulators;
  • Issued Preemption Determination;
  • Issued Second Round of Clarifications to Mortgage Rules; and
  • Testified before the Senate Banking Committee.

Summaries on each of these are included in our Government Relations update below. For me, the most important takeaway from Tuesday's CFPB hearing was the Bureau's Big Data collection and the lack of clarity regarding the intent and scope of this initiative. In addition, the exchange between Director Cordray and Sen. Warren regarding arbitration served as a major reminder about the Bureau's study and the impact their findings may have when published later this year. The CFPB will have the authority to restrict mandatory arbitration if their own study determines it is harmful to consumers. 

Deposit Advance Products - Who is on first, What is on second, and I Don't Know is on Third...

There are four different regulators overseeing the new mortgage rules and now there are four regulators opining on Deposit Advance Products (DAP). Just a day apart, the CFPB released their study, the FDIC and OCC issued guidance and the Federal Reserve issued a policy statement. There is a clear difference between a payday loan and a DAP, about which we continuously work to educate lawmakers and the press.



Whether banks are too big to fail continues to be a major issue in Washington, DC. While many Members of Congress are introducing legislation, we do not expect passage of any item over the next 18 months. However, Congressional pressure may force regulators to take action to ensure too big to fail does not exist. 

Thank You, CBA Members!

CBA would like to welcome our newest Corporate Member, GE Capital, to the CBA family. Thank you to Margaret Keane and Jonathan Mothner for your leadership in the decision to bring GE Capital into the fold. GE Capital joins CBA as our sixth new Corporate Member in the past year, along with Bank of Hawaii, California Bank & Trust, EverBank, Green Dot Bank, and Mainsource Financial. 

We are proud to announce 100% of our Corporate Members have renewed with CBA for 2013! Thank you to all of our members, both new and long-standing, for your constant support and patronage. We are excited to continue working with all our members during these tumultuous times! 


The deadline to apply to banking school is May 15, 2013, and enrollment is limited. Visit our website to read stories from graduates, faculty members and decision-makers about why they chose GSRBM.