The Honorable Jesus “Chuy” Garcia U.S. House of Representatives Washington, D.C. 20515 Dear Representative Garcia: On behalf of the Conference of State Bank Supervisors (CSBS), [1] I write to express our concern regarding legislation Congress is considering eliminating the exemption for industrial loan companies (“ILCs”) from the definition of a bank under the Bank Holding Company Act (“BHCA”). State regulators

As stated in our November 2016 comment letter to the OCC state bank regulators oppose the creation of a special purpose national bank charter for financial technology (fintech) and other nondepository companies because: The OCC lacks statutory authority to issue such a charter; Such a charter will distort the marketplace for financial services, with a federal agency arbitrarily picking winners

State regulators remain firmly opposed to the Comptroller’s unprecedented, unlawful expansion of its chartering authority to create a national nonbank charter. As we have discussed at length in previous comment letters, the OCC lacks the requisite authority to issue the proposed nonbank charter. Courts have long held and Congress has long since affirmed that a national bank must possess and

The Conference of State Bank Supervisors (“CSBS” or “state regulators”) is the nationwide organization of state regulators from all 50 states, American Samoa, the District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands. CSBS supports the state banking agencies by serving as a forum for policy and supervisory process development, and facilitates state implementation of policy through training

The Conference of State Bank Supervisors (“CSBS” or “state regulators”) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) request for information regarding the small business lending market and section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“DFA 1071”). CSBS is the nationwide organization of state banking and financial services regulators

A CSBS Comment Letter to the OCC, Board and FDIC to amend regulations requiring appraisals of real estate for certain transactions.

This is a list of archived CSBS Comment Letters dating from 2015 to 2016. For additional comment letters, please contact the CSBS Regulatory Team

Proposed changes by federal regulators are intended to simplify capital rules. Regulators need to go farther, says CSBS.

While state regulators are supportive of the removal of duplicative guidance, we believe that additional clarity is needed regarding the proposed changes to the communication of examination findings.