Bureau of Consumer Financial Protection Office of Management and Budget Attn: OMB Desk Officer New Executive Office Building, Room 10235 Washington, DC 20503 Docket No. BCFP-2018-00024 Re: Request for Comment Regarding the Bureau’s Consumer Complaint Intake System Company Portal Boarding Form Dear Office of Management and Budget: The Conference of State Bank Supervisors (“CSBS” or “state regulators”) appreciates the opportunity
VIA E-Mail December 4, 2018 Robert E. Feldman, Executive Secretary Attention: Comments Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429 Docket No. RIN 3064-ZA02 Re: Request for Information on FDIC Communication and Transparency Dear Mr. Feldman, The Conference of State Bank Supervisors 1 (“CSBS” or “state regulators”) appreciates the opportunity to comment on the Federal Deposit Insurance
State regulators believe that a robust market for consumer lending depends upon viable market alternatives. Thus, it is critically important that banks, and especially community banks, be able to serve as a source of small-dollar credit in the communities they serve.
Access the Full Letter [PDF] Paul Watkins, Assistant Director Attention: Comment Intake Consumer Financial Protection Bureau Office of Innovation 1700 G Street NW Washington, D.C., 20552 Re: Request for Comment on the Bureau’s Proposed Policy Guidance and Procedural Rule on No-Action Letters and Product Sandbox [Docket No. CFPB-2018-0042] Dear Mr. Watkins, The Conference of State Bank Supervisors (CSBS) appreciates the
CSBS strongly opposes the federal agency's plan to change the Community Bank Leverage Ration in way that may actually increase the burden on community banks, despite how the framework for the rule was intended to be drafted.
When considering possible legislation on consumer privacy and security, state regulators call on federal policymakers to maintain a floor upon which states can add more stringent conditions and respond more quickly to emerging threats
CSBS strongly opposes the federal agency's plan to change the Community Bank Leverage Ration in way that may actually increase the burden on community banks, despite how the framework for the rule was intended to be drafted.
While state regulators support maintaining fair and appropriate pricing of deposit insurance for institutions that use the CBLR, we believe that the proposed revisions to the deposit insurance assessment system are ultimately unnecessary because the CBLR should be defined as a Tier 1 leverage ratio.
In a comment letter to the FDIC, CSBS suggested changes to the regulatory treatment of brokered deposits and deposit interest cap methodology. Access the full letter [PDF] here.