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Staff Analysis
Laws Regarding Returned Checks
March 01, 2023
Check fraud is again on the rise, in part fueled by fraudsters who increasingly steal checks from U.S Postal Service mailboxes and offices, and even Postal Service workers and, after counterfeiting or washing and altering them, deposit them using remote deposit capture (through a mobile phone or an ATM) which makes alterations, counterfeits, and forgeries more difficult for banks to detect.
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Letter to Congress & Regulators
Letter to CFPB on P2P Payments and Scams
October 27, 2022
Our letter discusses some of the scams banks and their customers are experiencing, steps banks take to prevent scams and other fraud, and the significant banking industry efforts to educate customers about how to avoid being a victim of fraud.
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Comment Letter
Letter to the Fed on the Regulation Implementing the Adjustable Interest Rate
August 29, 2022
ABA appreciates the Board's efforts to complete implementation of the Act so that banks and other market participants can continue moving forward expeditiously to complete the transition from LIBOR and, in particular, to realize the benefits of the Act's provisions to address "tough legacy" contracts. To further that goal, ABA recommends that the Board address three additional points, described in the letter.
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Comment Letter
Letter to CFPB on Consumer Reporting in Cases of Human Trafficking
May 09, 2022
We agree that blocking adverse information in consumer reports that is a result of trafficking is an important way to help victims establish independence and financial stability and escape their abusers. It is also important, however, to balance this goal with ensuring that information in consumer reports is reliable and accurate.
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Staff Analysis
Proposal Prohibiting Inclusion of Adverse Information in Consumer Reports
April 21, 2022
The Bureau has published for comment a proposal to implement §6102 of the 2022 NDAA which amended the FCRA to prohibit consumer reporting agencies (CRA) from furnishing a consumer report containing any adverse item of information concerning a consumer that resulted from a severe form of trafficking in persons or sex trafficking if the consumer has provided trafficking documentation to the CRA.
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Staff Analysis
CFPB’s 2022 Report of Credit and Consumer Reporting Complaints
January 13, 2022
Pursuant to 611(e)(5) of the Fair Credit Reporting Act, the CFPB released its report summarizing information it gathered regarding certain consumer complaints transmitted by the CFPB to the three largest nationwide consumer reporting agencies - Equifax, Experian, and TransUnion.
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Backgrounder
Interest Rate Cap Issue Update
February 22, 2021
Interest Rate Caps Will Reduce Credit for Millions of Consumers
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Comment Letter
Letter to CFPB on the Request for Information Regarding the Consumer Credit Card Market
October 27, 2020
ABA's letter covers six topics: (I) Access and Availability, (II) Rewards, (III) Essential Market Practices and the Risks of Overregulation, (IV) Disclosures and E-SIGN, (V) Banking Industry Response To COVID-19, and (VI) Credit Reporting. Pursuant to the Bureau's request, we have listed the relevant questions from the Request for Information in each section.
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Backgrounder
Usury Caps Snapshot
March 12, 2020
H.R. 5050 Will Reduce Credit for Millions of Consumers
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Staff Analysis
Amendments to the Interpretive Rule of the Military Lending Act Rule
March 09, 2020
On Feb. 28, 2020, the Department of Defense published in the Federal Register its withdrawal of Question and Answer 2 (Q&A2) to its amended Interpretive Rule to its Military Lending Act Rule.
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Staff Analysis
Summary of Bills Amending the Fair Credit Reporting Act
February 13, 2020
ABA summary of the bills as marked up by the House Financial Services Committee July 11, 2019.
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Staff Analysis
Summary of Fall 2019 CFPB Supervisory Highlights: FCRA Furnisher Provisions
December 17, 2019
ABA summary of the CFPB's Fall 2019 Supervisory Highlights related to FCRA and Regulation V.
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Staff Analysis
9th Circuit Decision re: Disputes Submitted by Credit Repair Organizations
August 27, 2019
ABA issued a summary on the 9th Circuit's ruling in a Fair Credit Reporting Act case involving a dispute sent by a credit repair organization to a credit reporting agency on behalf of a consumer.
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Comment Letter
Letter to CFPB on the Plan for the Review of Bureau Rules Pursuant to the Regulatory Flexibility Act
July 15, 2019
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Staff Analysis
Amendments to Regulation CC (Expedited Funds Availability Act)
July 03, 2019
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Comment Letter
ABAs Letter to CFPB on the Request for Information Regarding the Consumer Credit Card Market
May 01, 2019
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Comment Letter
Letter to FDIC on Small Business Lending Survey
December 07, 2015
The American Bankers Association appreciates the opportunity to comment on the Federal Deposit Insurance Corporation's (FDIC) Paperwork Reduction Act request for approval of its proposed 'Small Business Lending Survey (Survey).'
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Comment Letter
ABA Comment on Request for Information on Credit CARD Act's Impact
February 19, 2013
Re: Notice and request for information regarding the credit card market; Section 502(a) of the Credit Card Accountability Responsibility and Disclosure Act of 2009; Docket No. CFPB‐2012‐0048; 77 FR 75410 (December 20, 2012)
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Staff Analysis
Final Rule on Credit Score Notices
August 04, 2011
ABA's summary of the Credit Scores Final Rule.
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Comment Letter
Fraud adjustment and fraud prevention standard provisions of Section 1075 of the Dodd Frank Act related to debit card interchange fees
November 08, 2010