comment letter

Joint Trades Comment Letter re H.R. 4773, Consumer Financial Protection Commission Act


Dear Representative Luetkemeyer:

The undersigned trade associations representing thousands of banks, credit unions, financial institutions, and businesses of all sizes that serve America’s consumers write to express our strong support for H.R. 4773, the Consumer Financial Protection Commission Act, that would transition the governance structure of the Consumer Financial Protection Bureau (CFPB) from a sole director to a five-person, bipartisan commission. This legislation, which is similar to bipartisan legislation in previous Congresses, has long been supported by the financial services industry.

A Senate confirmed, bipartisan commission will provide a balanced and deliberative approach to supervision, regulation, and enforcement by encouraging input from all stakeholders. The current single director structure leads to uncertainty as administrations transition. This uncertainty is not only borne by financial institutions providing significant lending services, but it negatively impacts America’s consumers, small businesses, and our local economies. Dramatic shifts in the CFPB’s philosophy and approach with each change in presidential administration make it difficult for lenders and small businesses to plan for the future.

The American people recognize the benefit of having certainty and stability from a bipartisan commission at the CFPB. A Morning Consult poll shows that by a margin of three to one, registered voters in eight states support a bipartisan commission over a sole director, with only 14 percent of those polled stating they prefer to keep the Bureau’s current leadership structure. Moreover, it is the traditional structure for a financial services regulator as this leadership model provides some moderation and stability regardless of who is in the White House.

We strongly support H.R. 4773 and look forward to working with you, the Committee, and the 117th Congress to pass this bill and have it signed into law. Thank you for your strong, common-sense leadership on such a critical issue.


ACA International

American Bankers Association

American Escrow Association

American Financial Services Association

American Land Title Association

ATM Industry Association

Broker Resource Network

Community Mortgage Lenders of America

Consumer Bankers Association

Consumer Credit Industry Association

Consumer Data Industry Association

Consumer Mortgage Coalition

Credit Union National Association

Electronic Funds Transfer Association

Electronic Transactions Association

Housing Policy Council

Independent Community Bankers of America

Mid-Size Bank Coalition

Mortgage Bankers Association

National Association of Federally-Insured Credit Unions

National Association of Independent Housing Professionals

National Association of Realtors

National Black Chamber of Commerce

National Independent Automobile Dealers Association (NIADA)

Real Estate Services Providers Council, Inc. (RESPRO)

Small Business & Entrepreneurship Council

The Realty Alliance

The U.S. Chamber of Commerce


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