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.
State regulators believe this framework has been effective in protecting consumers. The proposed amendments to the Safeguards Rule would bolster the consumer protections ensured by the rule and would not prevent states from imposing stricter requirements.
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
In this letter, CSBS raises concerns regarding the impetus for and permissibility of these contemplated proposals and reiterates concerns regarding the validity of the OCC’s multistate fiduciary operations rules.
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.