Comment Letters
Section 1071 Small Business Lending Data Collection
This letter addresses the proposed rule from the Consumer Financial Protection Bureau (Bureau) amending Regulation B to implement changes to the Equal Credit Opportunity Act made by section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).
SB 1235: Clear and Consistent Disclosures
On April 26, 2021, CBA filed a comment letter to the California Department of Financial Protection and Innovation on the implementation of SB 1235, a measure which requires lenders and other commercial financing companies to provide clear and consistent disclosures to small business owners.
CBA Submits Additional Comment Letter on Definition of a Depository Institution
CBA has previously provided comments on this matter and CBA strongly reiterates its position that subsidiaries, affiliates and entities otherwise related to depository institutions, which are engaged in the business of commercial lending under federal regulatory oversight should be exempted from application of the proposed regulations in the same manner that depository institutions are exempted.
Specifically, CBA requests that a definition of “depository institution” should be added to the proposed regulations as follows:
CBA Submits Comment Letter on Definition of a Depository Institution
CBA has previously provided comments on this matter on January 22, 2019, and again on September 9, 2019. CBA strongly reiterates its position that subsidiaries, affiliates and entities otherwise related to depository institutions, which are engaged in the business of commercial lending under federal regulatory oversight should be exempted from application of the proposed regulations in the same manner that depository institutions are exempted.
CBA Submits Comment Letter on Brokered Deposits
Our letter provides comments on the proposed revisions to the Brokered Deposits Restrictions regulation promulgated by the Federal Deposit Insurance Corporation (FDIC).
While we are generally supportive of the efforts to modernize these regulations, we do believe that some aspects of the proposal should be clarified to avoid ambiguity and unintended consequences.
Click here to view our letter.
CBA Submits Public Bank Comment Letter to DBO
This week, CBA submitted its comment letter to the Department of Business Oversight regarding the proposed rulemaking relative to public banks.
Click here to read the letter.
CBA Submits CRA Modernization Comment Letter
CBA submitted comments this week to The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation on a proposed rule to modernize the Community Reinvestment Act. The proposed rule focuses on improvement in the areas of qualifying activities, assessment areas, performance standards, and data collection.
We also have worked with the American Bankers Association (ABA) on a joint comment letter regarding the proposed regulations.