comment letter

CBA Submits Comments on CFPB’s Proposed NSF Rule


To Whom it May Concern:

The Consumer Bankers Association (CBA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (the CFPB or Bureau) Notice of Proposed Rulemaking on Fees for Instantaneously Declined Transactions (the Proposal or Proposed Rule). Under the Proposed Rule, one-time debit transactions, ATM transactions, and person-to-person transactions would be covered. The Bureau states it has preliminarily concluded that the targeted fees are abusive under the Consumer Financial Protection Act (CFPA) because they represent unreasonable advantage-taking of consumers who lack awareness of the risks, costs, or conditions of a financial service or product.

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