comment letter

CBA Sends Letter to Senate Banking Ahead of CFPB Semi-Annual Hearing


Dear Chairman Brown and Ranking Member Scott

The Consumer Bankers Association (CBA) submits the following comments for the hearing entitled “The Consumer Financial Protection Bureau’s Semi-Annual Report to Congress.” We appreciate the committee’s continued oversight of the Consumer Financial Protection Bureau (CFPB or Bureau) and its activities. 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.

The CFPB was created in 2011 by the Dodd-Frank Act and has seen no significant changes to its structure since it became operational. Since its inception, the Bureau has been a political lightning rod, instead of a steady and consistent voice for consumer protection regulation expected from a world class regulator. Recent actions taken by the Bureau have established new regulatory requirements for banks outside of the rulemaking process required by the Administrative Procedure Act, and, under the current leadership, the Bureau seeks 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 current Director’s nearly constant and public attacks on banks erode consumer confidence in the banking system and undermine efforts to bring more consumers into highly regulated and time-tested depository intuitions.

In this letter, we offer legislative and regulatory suggestions to lawmakers and the Bureau for the purpose of ensuring consumers continue to have access to highly regulated financial products that enable them to achieve their financial goals. Topics discussed include: (1) credit card late fees, (2) Dodd-Frank Section 1071 implementation, (3) needed changes to the Bureau’s UDAAP authority, and (4) structural reforms to the Bureau.


To read the full letter, click HERE.


    Sign up to receive our press releases and blogs.