Agency Acronyms
CFPB – Bureau of Consumer Financial Protection
FRB – Board of Governors of the Federal Reserve System
FDIC – Federal Deposit Insurance Corporation
OCC – Office of the Comptroller of the Currency
FinCEN – Financial Crimes Enforcement Network
NCUA – National Credit Union Administration
FEMA – Federal Emergency Management Agency
Why Comment Letters Matter
Comment letters are an excellent opportunity for the banking industry to inform the federal agencies about the impact of rulemaking, and provide examples. It is crucial that WBA represent the best interests of members at the federal level, whether that means pointing out potentially onerous, unfair, or burdensome rules, suggesting tweaks or improvements, or expressing satisfaction when positive changes are being implemented. The goal is to advocate on behalf of members by conveying information in an impactful, yet concise manner.
Fiscal Year 2022–23 Comment Letters
- FDIC Statement of Principles for Climate-Related Risk (06.07.22)
- SEC Climate Risk Disclosure Proposal (06.15.22)
- FRB, FDIC, and OCC Proposed CRA Revisions (08.05.22)
- FDIC Proposed Deposit Insurance Assessment Rates (08.19.22)
- FDIC, OCC, and NCUA’s Proposed Policy Statement on Prudent Commercial Real Estate Loan Workouts (10.03.22)
- FHFA Review of the FHLB System (10.31.22)
- CFPB RFI on Refinances (11.28.22)
- CFPB Data Privacy Summary of Proposals (01.25.23)
- FinCEN Beneficial Ownership Information Access (02.15.23)
- FDIC Proposed Official Sign and Advertising Requirements (04.07.23)
Fiscal Year 2021–22 Comment Letters
- FRB Reg O Loans to Executive Officers, Directors & Principal Shareholders (07.06.21)
- FDIC False Use of FDIC Name (07.09.21)
- FRB Guidelines for Evaluating Account and Services Requests (07.12.21)
- FDIC RFI on Digital Assets (07.16.2021)
- FRB NPRM Interchange Fees (08.11.21)
- FDIC Proposal to Simplify Deposit Insurance Rules (10.04.21)
- FDIC Request for Information on Supervisory Approach to Bank Examinations During the Pandemic (10.12.21)
- FRB, FDIC, OCC Proposed Interagency Guidance on Third-Party Relationships, Risk Management (10.18.21)
- OCC Community Reinvestment Act Regulations (10.29.21)
- CFPB Small Business Lending Data Collection (01.06.22)
- HMDA Assessment (01.21.22)
- CFBP RFI Regarding “Junk Fees” (03.31.22)
- FDIC Post-Exam Survey (04.25.22)
- FRB Discussion Paper on Central Bank Digital Currency (05.20.22)
- HUD FHA Modifications (5.24.22)
- FDIC Bank Merger Act (5.31.22)
Fiscal Year 2020–21 Comment Letters
- FRB,FDIC, OCC Proposal to Allow Deferral of Obtaining Appraisals* (06.01.20)
- FRB Proposal to Revise Reg O to Allow PPP Loans to Executive Officers* (06.08.20)
- FDIC Brokered Deposit Rule, Recommendations to Proposed Rule (06.09.20)
- FRB Revisions to Regulation D to Remove Withdrawal Restrictions from Savings Deposits* (06.29.20)
- NCUA Subordinated Debt Proposal, Recommended Withdrawal of Rule (07.08.20)
- CFPB Rules Regarding Transition from LIBOR as Index for Loan (08.04.20)
- CFPB Proposal to Extend Temporary GSE QM Exemption Until General QM Rule is Finalized (08.10.20)
- CFPB Interim Rule Regarding Loss Mitigation Option Due to COVID* (08.14.20)
- FRB Extension of Exemption in Reg O to Allow PPP Loans to Executive Officers* (08.31.20)
- CFPB Revision to General QM Rule (09.08.20)
- CFPB Exemption from Escrow for Certain HPMLs (09.21.20)
- CFPB Creation of Seasoned QM (09.25.20)
- FRB, FDIC, OCC, FEMA, NCUA Revisions to Flood Act Interagency FAQ Guidance (11.03.20)
- FRB, FinCEN Lower Reporting Threshold and Include Cryptocurrency in Travel Rule (11.27.20)
- CFPB DFA Section 1071 Proposal (12.14.20)
- OCC CRA General Performance Standards (02.02.21)
- NCUA Field of Membership-Shared Facilities Requirements (02.10.21)
- FRB ANPR on CRA (02.16.21)
- FRB SAR Exemptions (02.22.21)
- OCC SAR Exemptions (02.22.21)
- FDIC SAR Exemptions (02.22.21)
- OCC Proposal to Modernize Bank Premises (03.22.21)
- NCUA CUSO Proposal (04.06.21)
- Administrative Ruling Request of FinCEN (4.21.21)
- FinCEN – Beneficial Ownership Information (05.05.21)
- Interagency Notice Regarding Private Flood Insurance Q&A (5.17.21)
- FDIC Official Sign and Advertising Rules (5.24.21)
* COVID-19 regulatory relief related issue
