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 a
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 filed a complaint in the U.S. District Court of D.C. against the OCC, seeking to prevent the agency from its unlawful attempt to create a national nonbank charter. A national nonbank charter will harm markets, innovation, and consumers.
As stated in our November 2016 comment letter to the OCC state bank regulators oppose the creation of a special purpose national bank charter for financial technology (fintech) and other nondepository companies because: