comment letter

Comments in Response to RFI Regarding Relationship Banking and Customer Service


August 22, 2022 


Comment Intake – Relationship Banking

Consumer Financial Protection Bureau

1700 G Street, NW

Washington, DC 20552


Re: Docket No. CFPB-2022-0040


Re: Comments in Response to Request for Information Regarding Relationship Banking and Customer Service, Docket No. CFPB-2022-0040


To Whom it May Concern:

The Bank Policy Institute,[1] the Consumer Bankers Association,[2] and the American Bankers Association[3]appreciate the opportunity to submit comments to the Consumer Financial Protection Bureau in response to the request for information “related to relationship banking and how consumers can assert the right to obtain timely responses to requests for information about their accounts from banks and credit unions with more than $10 billion in assets, as well as from their affiliates.”


I. Executive Summary

The provision of the Dodd-Frank Act on which the CFPB relies to issue the RFI—section 1034(c)—states that banks “shall, in a timely manner, comply with a consumer request for information” concerning the consumer financial product or service that the consumer obtained from the bank.[1] Section 1034(c) is not a customer service provision and does not authorize the CFPB to regulate customer service or set the terms of how, when, or where banks serve their customers. The CFPB would exceed the authority Congress gave the agency were it to attempt to do so.

Banks of all sizes take very seriously the important role they play in the financial lives of consumers, families, businesses, communities, and the nation’s economy. Banks provide products and services that help consumers meet their financial needs, and they are continuously innovating to better serve customers in this highly competitive marketplace. To ensure customers with diverse needs and preferences are able to take full advantage of the products and services banks offer, banks serve customers through a variety of channels, including at branches, online, through mobile applications, and over the telephone.


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