comment letter

Joint Trades Comment on CFPB”S Inquiry into Big Tech Payment Platforms


To Whom It May Concern:

The American Bankers Association (ABA),1 the Consumer Bankers Association (CBA),2 and the Credit Union National Association (CUNA)3 appreciate the opportunity to submit comments to the Consumer Financial Protection Bureau (CFPB) in response to CFPB’s notice and request for additional comments regarding CFPB’s inquiry into big tech payment platforms.4 As we have previously stressed, and recent crypto events demonstrate, consumers can face appreciable risks when underregulated nonfinancial companies achieve significant scale as de facto financial intermediaries, including for payments.

Our members believe that regulators must move beyond monitoring nonbank payments markets and toward action that ensures nonbank payments do not develop into full-fledged shadow banking. A series of actions by CFPB indicate that the agency is accelerating its scrutiny.5 Last month, CFPB published a final rule amending its procedural rule on supervision of nonbank entities based on risk factors and additionally has commenced its rulemaking on personal financial data rights, which necessarily will include nonbank participants in the ecosystem. We urge CFPB to continue to increase its oversight until all consumers are protected at a consistent level, no matter the legal structure of the entity.

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