CBA Submits Comments on BCFP Adopted Regulations

June 20, 2018

On Wednesday, June 20, 2018, CBA submitted comments to BCFP’s request for information on adopted regulations and new rulemaking authorities. In the letter, CBA focused on recommendations designed to promote consumer access to credit, encourage the use of digital channels and improve regulatory compliance.


“We applaud the Bureau’s openness to receiving public input regarding the substance of the adopted regulations,” CBA Vice President and Senior Counsel Dong Hong wrote. “A robust assessment of these regulations is timely and CBA’s members welcome changes to the rules that will allow them to serve their customers in a more efficient and effective manner.”


CBA’s comment letter provides specific recommendations for adopted regulations to improve the customer experience and functioning of consumer financial markets, specifically:


 - Mortgage Related Rules

  •  Ability to Repay Rule and Qualified Mortgage Standards
  •  Mortgage Servicing
  •  Loan Originator Compensation Rule
  •  TILA-RESPA integrated Disclosure (TRID) Rule


 - Non-Mortgage Rules

  •  Remittance Rule
  •  Prepaid Accounts
  •  Larger Market Participant Rules
  •  No-Action Letter Policy
  •  Data Aggregation Principles