Cyber-Security

CBA supports strong national data protection and consumer notification standards with effective enforcement provisions that are applicable to any party with access to important consumer financial information. CBA members are already subject to robust data protection and notification standards and these requirements must be recognized. Inconsistent state laws and regulations should be preempted in favor of strong Federal data protection and notification standards. CBA firmly holds that all parties must share in protecting consumers and, as such, the costs of a data breach should ultimately be borne by the entity that incurs the breach. Protecting consumer data is a shared responsibility, and merchants must have the same tough data security standards as financial institutions to thwart hackers as well as the ability to accept chip-based cards.
  • April 19, 2017
    On Wednesday, April 19, 2017, the Government Accountability Office (GAO) released a report on the fintech industry in response to a request from Sens. Sherrod Brown (D-OH), Jeanne Shaheen (D-NH) and Jeff Merkley (D-OR). The GAO stated there is “universal definition of fintech,” it can be loosely understood to encompass specific subsectors likely to have greatest impact on traditional financial...
  • April 14, 2017
    The OCC recently offered a proposal to charter fintech companies by amending the Comptroller’s Licensing Manual with a new supplement covering fintech companies. On April 14, 2017, CBA offered a comment letter in response to this proposal, crediting the OCC for granting its request for additional information and for making certain adjustments to its original proposal. However, CBA reiterated its...
  • March 22, 2017
    Download Whitepape r. KPMG LLP (KPMG) is pleased to announce the release of the new point-of-view document related to our Chief Compliance Officer (CCO) Survey findings , The compliance journey: Boosting the value of compliance in a changing regulatory climate . In a time of new U.S. administrative impacts to the regulatory environment, determining how to boost the value you get from your...
  • March 15, 2017
    Even the more sophisticated data-driven financial services marketers are struggling to figure out how to effectively and efficiently integrate personalization into multichannel customer and prospect marketing strategies. This iteration of the Epsilon 5 & 5 is intended to trigger some contrarian thoughts and challenge your marketing status quo. In this issue, we’ll talk about personalization,...
  • March 10, 2017
    March 10, 2017 The Honorable Scott Tipton The Honorable Randy Hultgren U.S. House of Representatives U.S. House of Representatives 218 Cannon House Office Building 2455 Rayburn House Office Building Washington, DC 20515 Washington, DC 20515 The Honorable Patrick McHenry The Honorable David Scott U.S. House of Representatives U.S. House of Representatives 2334 Rayburn House Office Building 225...
  • February 21, 2017
    On Tuesday, February 21, 2017, CBA submitted comment on the CFPB’s Request for Information on Consumer Access to Financial Data. CBA supported the innovation and implementation of data aggregation services, and the ability of consumers to access personal data in order to efficiently manage finances. “If implemented correctly, we believe data aggregation can be a useful consumer tool to protect...
  • February 21, 2017
    February 21, 2017 Submitted Electronically: FederalRegisterComments@cfpb.gov Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Docket No.: CFPB-2016-0048 / Document No.: 2016-28086 - Request for Information Regarding Consumer Access to Financial Records Dear Ms. Jackson, The Consumer Bankers Association (“CBA”) [1...
  • January 13, 2017
    On Friday, January 13, 2017, in a letter to the OCC, Rep. Gregory Meeks (D-NY) with Reps. Tony Cardenas (D-CA), Gwen Moore (D-WI), Donald Payne, Jr. (D-NJ), Cedric Richmond (D-LA), and Terri Sewell (D-AL), asked the agency include measurable and enforceable financial inclusion requirements for fintech firms receiving national charters, similar to those required of banks under the Community...
  • January 5, 2017
    On Thursday, January 5, 2017, the OCC issued its Fall Semiannual Risk Perspective , covering January to June of 2016. As in past reports, strategic, credit, operational and compliance risk were top concerns. However, leveraged lending – a top concern in the past – has diminished in focus, while governance over sales practices rose to the level of a key risk area. Key findings include: Strategic...

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