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:

“Depository institution” means any of the entities defined under section 22800, subdivision (h) of the Code and includes any non-depository subsidiaries, affiliates and other entities related to such depository institutions that are subject to supervision and regulation by federal banking regulators.”