The American Bankers Association, the Consumer Bankers Association and The Financial Services Roundtable (Associations) have filed a joint letter commenting on the final results of the CFPB’s arbitration study released in March 2015. Ballard Spahr served as counsel to the Associations in preparing the comment letter.
Section 1028 of the Dodd-Frank Act requires the CFPB to conduct a study of the use of arbitration in consumer financial services agreements and authorizes the CFPB to limit or prohibit the use of arbitration based on the CFPB’s findings. In June 2012, the Associations submitted comments in response to the CFPB’s Request for Information Regarding Scope, Methods, and Data Sources for Conducting Study of Pre-Dispute Arbitration Agreements. Ballard Spahr also served as counsel to the Associations in preparing that comment letter.