CSBS has consistently maintained that access to Federal Reserve services should be restricted to eligible institutions on an equitable and impartial basis. We are concerned that this proposal assumes state supervision is substandard to federal supervision.
State regulators remain concerned about the ability of lenders to use the internet to reach borrowers in states where payday lending is restricted. The Bureau’s 2017 Rule would not have prevented illegal payday lending, but its implementation would have instituted nationwide compliance requirements backed up by the Bureau’s examination authority.
The Honorable Mitch McConnell Majority Leader United States Senate Washington, DC 20510 The Honorable Charles Schumer Minority Leader United States Senate Washington, DC 20510 Dear Majority Leader McConnell and Minority Leader Schumer: On behalf of the Conference of State Bank Supervisors (CSBS), I am writing to express state bank regulators’ continued support for Michelle Bowman’s nomination to a full term
The proposed rule states that currently, validation notices, combined with the limited disclosure of consumers’ rights with respect to debt collection, may limit a consumer’s ability to fully exercise their dispute rights.
The proposed national rate cap methodology should not allow the largest institutions to exercise undue influence on the national rate. The local rate cap calculation and process should factor in rates offered by internet-only banks.
State bank regulators view the development of FedNow as the Federal Reserve again laying the necessary foundation to ensure that payment capabilities adapt to innovation and technological advancement.
State regulators across the country have a wide diversity of views and supervisory responsibilities over financial institutions that may be (or may be interested in) providing services to cannabis-related legitimate businesses (CRLBs). This diversity reflects the various and evolving nature of many states’ legal regimes and their treatment of different types of cannabis products.
State regulators offer legislative proposals aimed at ensuring the safety and soundness of individual state-regulated entities, the broader financial markets, and the protection of consumers and small businesses in light of the current COVID-19 pandemic.