CSBS President and CEO John Ryan writes the Senate Banking Committee in support of the Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155).
Despite the rarity of waiver applications, state regulators believe that limited availability of qualified appraisers in numerous markets is impacting the ability of many banks to fulfill the credit needs of the communities they serve.
Maintaining the primary role of the state regulatory system is critical to ensuring the continued protection of consumers and maintaining the strength and competitiveness of the non-bank financial services industry.
State regulators firmly oppose the provisions of the PROSPER Act preempting state servicing laws. The preemption provisions upset the historical federal-state balance in financial regulation and wrongfully interfere with traditional state enforcement authority.
In revising its existing procedures and standards with respect to CIDs and associated processes, we encourage the CFPB to do so in a manner that recognizes that state regulators serve as the primary regulators of non-depositories
Monica Jackson, Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC Docket No. CFPB-2018-0003 Re: Request for Information Regarding Bureau Enforcement Processes Dear Ms. Jackson, 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 Bureau
Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551 Docket No. R-1599; RIN 7100-AE98 Re: Collection of Checks and Other Items by Federal Reserve Banks and Funds Transfers Through Fedwire. Dear Sir or Madam, The Conference of State Bank Supervisors (the “CSBS” or “state bank regulators”) 1 appreciate
State regulators firmly oppose H.R. 4439, the Modernizing Credit Opportunities Act, as it would allow bad actors to exploit banks’ federal preemption to issue harmful loans to consumers in contravention of state law.