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
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.
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.