comment letter

CBA Letter to Subcommittee on Financial Institutions and Monetary Policy ahead of “Consumer Financial Protection Bureau: Ripe for Reform” Hearing


Dear Chairman Barr and Ranking Member Foster:

The Consumer Bankers Association (CBA) is pleased to submit this letter for the hearing entitled “Consumer Financial Protection Bureau: Ripe for Reform.” We appreciate the committee’s attention to meaningful CFPB reforms to ensure a safe and well-functioning financial services marketplace. CBA is the voice of the retail banking industry whose products and services provide access to credit to millions of consumers and small businesses. Our members operate in all 50 states, serve more than 150 million Americans, and collectively hold two-thirds of the country’s total depository assets.

Significant reforms to the CFPB are long overdue. Since its inception, the Bureau has been a political lightning rod, instead of a steady and consistent voice for consumer protection regulation and best practices expected from a world class regulator. Recently, creative messaging aimed to sway the court of public opinion– rather than informed regulatory decisions that have received input from all stakeholders– appears to guide the decision making at the Bureau, and its policy proclamations are often based on ideological preferences rather than on data and stakeholder feedback. This often creates confusion for providers of consumer financial services and the customers they serve. Another worrisome trend at the Bureau is its willingness to establish new regulatory requirements for banks outside of the rulemaking process required by the Administrative Procedure Act while seeking minimal input from the industry it is responsible for overseeing. This is in stark contrast to the open dialogue that the banking industry experienced with multiple previous CFPB Directors, regardless of party affiliation. Furthermore, the Director’s nearly constant and public attacks on banks erode consumer confidence in the banking system and undermine efforts to bring more consumers into the highly regulated and time-tested depository intuitions the Bureau oversees.

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