comment letter
CBA Submits Comments on CFPB’s Proposed Overdraft Rule
To Whom It May Concern:
The Consumer Bankers Association (“CBA”) 1 greatly appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (the “CFPB’s” or “Bureau’s”) notice of proposed rulemaking for Overdraft Lending: Very Large Financial Institutions (the “Proposal”).2 The Proposal would fundamentally restructure and restrict consumer overdraft services offered by banks that exceed $10 billion in assets, referred to in the Proposal as Very Large Financial Institutions.3 CBA believes overdraft services offered by banks with assets of less than or equal to $10 billion would also likely suffer significant indirect effects from the Proposal.
