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Regulatory Comment Letters Archive

2012

2011

2010

2009

2008

2007

  • Comment Letter on Prohibition on Funding of Unlawful Internet Gambling (December 12, 2007)
    PDF format, 43KB
    This Comment Letter was submitted to the Federal Reserve and the Department of the Treasury on behalf of CBA regarding financial institution regulatory agencies proposing regulations to require banks to block illegal gambling transactions.

  • CBA Comment Letter on Proposed Guidance on Garnishment Orders Affecting Exempt Benefit Payments (November 27, 2007)
    PDF format, 65KB

  • CBA Comment to the OTS re Advance Notice of Proposed Rulemaking; Unfair or Deceptive Acts or Practices; 12 CFR, Part 535 (November 5, 2007)
    PDF format, 41KB

  • CBA Comment Letter to the Federal Reserve Board on Regulation Z Open-End Review (October 12, 2007)
    PDF format, 73KB

  • CBA Comment on the Regulatory Agencies’ Proposal to Amend the CRA Q&A (September 10, 2007)
    PDF format, 91KB

  • CBA Comment Letter to the FTC on use of Social Security Numbers (September 5, 2007)
    PDF format, 55KB

  • CBA Comments on HOEPA (August 15, 2007)
    PDF format, 72KB
    The Consumer Bankers Association ("CBA") appreciates the opportunity to comment on the issues raised by the Federal Reserve Board (the "Board") under its Home Ownership and Equity Protection Act of 1994 ("HOEPA") authority.

  • FFELP Community Loan NPRM Final Comments (August 10, 2007)
    PDF format, 325KB
    This letter is in response to the request for comments on the Notice of Proposed Rulemaking (NPRM) for federal student loan programs published on June 12, 2007 in the Federal Register (Volume 72, Number 112). The undersigned student loan trade associations hereby submit the attached comments.

  • Ways and Means Final (July 17, 2007)
    PDF format, 37KB
    The undersigned companies and trade associations, which collectively represent millions of companies, tens of millions of employees, and hundreds of millions of customers, are writing to express our concerns with H.R. 3046, the "Social Security Number Privacy and Identity Theft Prevention Act of 2007."

  • CBA Comment Letter Against College Cost Reduction Act of 2007 (July 2, 2007)
    PDF format, 33KB

  • CBA Comment Letter on Electronic Disclosures Under Regulations B, E, M, Z, and DD (June 29, 2007)
    PDF format, 46KB
    This letter is submitted by the Consumer Bankers Association ("CBA") in response to the proposal by the Board of Governors of the Federal Reserve System (the "Board") to amend several regulations relating to the delivery of electronic disclosures pursuant to Regulations B, E, M, Z and DD (the "Proposed Rules").

  • CBA Letter on Higher Education Access Act reconciliation in the Senate HELP Committee (June 21, 2007)
    PDF format, 40KB
    We want to again thank you for the opportunity to meet with you and Mr. Fallon to discuss proposed Regulation R, which implements certain exceptions for banks from the definition of the term “broker” under Section 3(a)(4) of the Securities Exchange Act of 1934 (the “Exchange Act”), as amended by the Gramm-Leach-Bliley Act.1 This letter responds to several questions raised during our meeting.

  • CBA Letter to Senate HELP Committee on Higher Education Act Reauthorization (June 19, 2007) (June 19, 2007)
    PDF format, 30KB
    Members of the Consumer Bankers Association engaged in the financing, making, and servicing of Federal Family Education Loans read with great interest the details of the Higher Education Access Act released this week. This letter is to express our very strong concerns regarding the budget cuts to the student loan programs included in the bill.

  • CBA Letter (June 11, 2007)
    PDF format, 28KB
    The Consumer Bankers Association ("CBA") welcomes the opportunity to comment on the Department of Defense’s (“Department”) proposed regulation (“Proposal”) to implement the consumer protections enacted in Public Law 109-364, the John Warner National Defense Authorization Act for the year 2007, commonly known as the ("Payday Loan Law").

  • CL Final Joint Letter June 2007 (June 11, 2007)
    PDF format, 106KB
    The undersigned trade associations representing insured depository institutions appreciate the opportunity to comment on the Department of Defense’s ("The Department") proposal to implement the consumer protections in Public Law 109-364, the John Warner National Defense Authorization Act for Fiscal Year 2007,) section 670, "Limitations on Terms of Consumer Credit Extended to Service Members and Dependents" ("Payday Loan Law"). The proposed rule is intended to regulate the terms of certain consumer credit to service members and their spouses and dependents.

  • Letter on HR 964 (June 5, 2007)
    PDF format, 23KB
    The undersigned companies and associations are writing to express our opposition to provisions within H.R. 964, which is scheduled to be considered by the full House of Representatives tomorrow, Wednesday, June 6. The “Spy Act” is supposedly intended to combat “spyware,” certain types of downloaded software that have taken over consumer computers. We strongly support legislative efforts to combat spyware and impose strong penalties on purveyors of such practices. For this reason, we supported another bill that was recently passed by the House, H.R. 1525, that imposes strong penalties on such bad actors.

  • Joint Trade Association Statement on Responsible Subprime Lending Principles (May 29, 2007)
    PDF format, 82KB
    Our trade associations believe that all mortgage lenders should embrace responsible subprime lending principles. We support the efforts by industry and the federal banking regulatory agencies to strengthen underwriting standards and to protect borrowers against unfair and deceptive mortgage lending practices.

  • Model Privacy (May 29, 2007)
    PDF format, 848KB

  • Subprime Statement - CBA Comment Final (May 7, 2007)
    PDF format, 96KB
    The Consumer Bankers Association ("CBA") appreciates the opportunity to comment on the Proposed Statement on Subprime Mortgage Lending ("Statement") issued by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, and the National Credit Union Administration ("Agencies").

  • Subprime Statement - CBA Comment Final (May 7, 2007)
    PDF format, 96KB
    The Consumer Bankers Association ("CBA") appreciates the opportunity to comment on the Proposed Statement on Subprime Mortgage Lending ("Statement") issued by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, and the National Credit Union Administration ("Agencies").

  • HR 273 Letter April 13 2007 (April 13, 2007)
    PDF format, 34KB
    The membership of the Consumer Bankers Association has taken a leadership role in providing financial education, offering instruction in every field of personal finance, including home ownership, foreclosure prevention, credit card usage, basic budgeting and a host of other topics relevant to the needs of our customers. CBA has found that such efforts have helped produce knowledgeable consumers with the financial skills needed for the responsible use of the products and services available today from our member banks.

  • Regulation R Comment Letter (3-26-07) (March 26, 2007)
    PDF format, 103KB
    This letter is submitted by the Consumer Bankers Association ( ("CBA") in response to the joint proposal of the Board of Governors of the Federal Reserve System (the "Board") and the Securities and Exchange Commission (the "Commission") (together, the "Agencies") requesting comment on proposed rules that would implement certain exceptions for banks from the definition of the term "broker" under Section 3(a)(4) of the Securities Exchange Act of 1934 (the "Exchange Act") and amended by the Gramm-Leach-Bliley Act (the “GLB Act”) (the "Proposed Rules").

  • Regulation R Comment Letter (3-26-07) (March 26, 2007)
    PDF format, 103KB
    This letter is submitted by the Consumer Bankers Association ("CBA") in response to the joint proposal of the Board of Governors of the Federal Reserve System (the "Board") and the Securities and Exchange Commission (the “Commission”) (together, the "Agencies") requesting comment on proposed rules that would implement certain exceptions for banks from the definition of the term "broker" under Section 3(a)(4) of the Securities Exchange Act of 1934 (the "Exchange Act") and amended by the Gramm-Leach-Bliley Act (the “GLB Act”) (the "Proposed Rules").

  • March 9 (March 9, 2007)
    PDF format, 24KB
    The Consumer Bankers Association, whose membership includes most of the nation’s largest bank holding companies as well as major regional banks, is pleased to submit this comment on the proposal by the Federal Deposit Insurance Corporation ('FDIC") to conduct a survey and study on usage and patterns of overdraft protection programs. Because CBA’s members are leaders in the retail banking industry, this issue is of critical interest to us. Overdraft protection is a service offered by banks under the jurisdiction of all of the bank regulatory agencies, so that the proposed survey and study by the FDIC is of interest to all of our membership.

  • March 9 (March 9, 2007)
    PDF format, 24KB
    The Consumer Bankers Association, whose membership includes most of the nation’s largest bank holding companies as well as major regional banks, is pleased to submit this comment on the proposal by the Federal Deposit Insurance Corporation ("FDIC") to conduct a survey and study on usage and patterns of overdraft protection programs. Because CBA’s members are leaders in the retail banking industry, this issue is of critical interest to us. Overdraft protection is a service offered by banks under the jurisdiction of all of the bank regulatory agencies, so that the proposed survey and study by the FDIC is of interest to all of our membership.

  • Bank Association Letter Re: Concerns About S.359 (February 7, 2007)
    PDF format, 95KB

  • Additional CBA Comments to the Department of Defense regarding Payday Lending Legislation (February 5, 2007)
    PDF format, 59KB

  • DOD Letter 2 (January 30, 2007)
    PDF format, 59KB
    The Consumer Bankers Association (CBA)1 appreciates the opportunity to respond to the Department of Defense (DOD) request for comments and recommendations (71 FR 70512; Dec. 5, 2006), on the consumer protection rules to implement Sec 670 of the John Warner National Defense Authorization Act for Fiscal Year 2007, Pub. L. 109-364 (the Payday Lending law).

  • DOD Letter 2 (January 30, 2007)
    PDF format, 59KB
    The Consumer Bankers Association (CBA) appreciates the opportunity to respond to the Department of Defense (DOD) request for comments and recommendations (71 FR 70512; Dec. 5, 2006), on the consumer protection rules to implement Sec 670 of the John Warner National Defense Authorization Act for Fiscal Year 2007, Pub. L. 109-364 (the Payday Lending law).

  • Short Process Letter No Signatures (January 12, 2007)
    PDF format, 48KB
    The undersigned trade organizations are writing to express strong concerns about a possible expansion of the Interagency Guidance on Nontraditional Mortgage Product Risks for federally regulated financial institutions without benefit of a full notice and comment period.

  • CBA Joint Industry Comment Letter to the Department of Defense regarding Payday Lending Legislation (January 5, 2007)
    PDF format, 129KB

  • DOD Payday Lending 1/5/2007 (January 5, 2007)
    PDF format, 129KB
    The undersigned trade associations representing insured depository institutions appreciate the opportunity to offer our views on the implementation of Section 670 of the John Warner National Defense Authorization Act for Fiscal Year 2007, Pub. L. 109-364, Section 670, "Limitations on Terms of Consumer Credit Extended to Servicemembers and Dependents" (hereafter, "Payday Law").

2006

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