American Bankers Association

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Based on the President’s executive order 13772 on The Core Principles for Regulating the United States Financial System, the American Bankers Association (ABA) submitted a white paper to Treasury Secretary Mnuchin that criticizes the revised Home Mortgage Disclosure Act (HMDA) rule adopted by the CFPB.

The executive order requires the Treasury Secretary, based on the core principles laid out in the executive order,  to identify the federal laws that promote and inhibit the regulation of the United States financial system. … Continue Reading

Since the CFPB issued its final rule for general purpose prepaid accounts on October 5, 2016, it has faced challenges from Congress and criticism from industry participants.  In recognition of the numerous compliance difficulties posed by the rule, the CFPB has indicated that it is amenable to making substantive changes to the rule, and on March 9, the CFPB proposed to delay the rule’s implementation date in response to feedback from the prepaid industry.… Continue Reading

A substantial portion of Director Cordray’s remarks yesterday at the American Bankers Association’s Annual Convention in New Orleans was directed at justifying the Bureau’s decision not to delay the January 2014 effective dates of the new mortgage rules. Mr. Cordray reminded bankers that if the CFPB had failed to complete the rules, most of Title XIV of Dodd-Frank “would have taken effect in its own right in January 2013” and they “already would have been living under those provisions for quite some time with no guidance to resolve ambiguities and subject to whatever interpretations the courts might eventually arrive at through litigation.”  … Continue Reading

The American Bankers Association has sent a letter to the CFPB responding to the CFPB’s June 2013 white paper reporting its initial data findings on overdraft programs. When the paper was issued, we observed that regulation by the CFPB seemed likely and commented that it would require considerable thought and creativity for the CFPB to appropriately protect consumers without depriving them of valuable overdraft services or unduly impairing bank revenues.… Continue Reading

As part of its on-going study of consumer arbitration mandated by the Dodd-Frank Act, the CFPB announced on June 7, 2013 that it is seeking funding from the Office of Management and Budget to undertake a telephone survey of 1,000 credit card holders to ascertain their awareness of and perceptions regarding the arbitration provisions in their contracts.… Continue Reading

Mercedes Kelley-TunstallThe American Bankers Association has invited me to speak at their series of telephone briefings on Unfair, Deceptive or Abusive Acts or Practices, or UDAAP. I will be a panelist for two of the briefings—”UDAAP Issues in Operations and Product Design” on July 10, 2012, and “Social Media and the UDAAP Impact” on July 24, 2012.… Continue Reading

On January 30, 2012, the American Bankers Association delivered a comment letter  to the CFPB in which it expressed strong disagreement with the CFPB’s proposed policy statement on “Disclosure of Certain Credit Card Complaint Data“. The ABA expressed concern that the complaint data will not help and may actually mislead consumers because it is “incomplete, unrepresentative, and unverified.”… Continue Reading

Banks that offer mortgage products are being buried in new regulations that are straining their compliance capabilities, increasing their costs and, for community banks, threatening the viability of their entire business model. That’s the message the American Bankers Association tried to send in its recent letter to Raj Date, President Obama’s replacement for Elizabeth Warren as Special Advisor to the Treasury Secretary on the CFPB.… Continue Reading