Member login
American Financial Services Association

AFSA Comments on the Several Amendments Regarding the FY2023 NDAA

Blog Posts

AFSA Comments on the Several Amendments Regarding the FY2023 NDAA

Today, AFSA commented on the several amendments under consideration before the House Rules Committee regarding the FY2023 National Defense Authorization Act (NDAA). Below is a quick summary of those amendments.

  • AFSA Supports the Perlmutter #107 Amendment.

The amendment would prohibit a federal banking agency from terminating a banking relationship with a legal business unless there is a valid reason that is not based solely on reputational risk. No highly regulated business, such as state-licensed consumer finance companies, should be unfairly targeted solely based on the political bias of a particular administration.

  • AFSA Opposes the Cicilline #209 Amendment.

This amendment limits arbitration for servicemembers and would favor class-action lawsuits that take years to be adjudicated, clog the court system, and result in comparatively small payouts. Servicemembers deserve the ability to settle disputes through arbitration, a more expedient process that yields greater payouts for consumers.

  • AFSA Supports the Dean # 543 Amendment.

This amendment would expand the usage of RON technology nationally and enable the notarization process to be completed with the notary and signer in different physical locations, using two-way audiovisual communication.

  • AFSA Opposes the Gottheimer #372 Amendment.

The credit reporting industry plays an integral role in deciding individuals’, especially servicemembers’, access to credit and that accurate information is crucial. We also agree that any errors should be addressed as quickly as possible. While improvements and system modifications can always be implemented, this amendment as drafted is duplicative and likely unnecessary for servicemembers.

  • AFSA Opposes the Torres #760 Amendment.

To collect and report demographic data about small businesses to the CFPB, covered financial institutions would be required to compile, maintain, and report information concerning credit applications made by a variety of small businesses with unique financial circumstances.

Implementing a small business data collection system of this magnitude, which may apply to multiple credit products and loan operation systems within each financial institution, will require the development of new data privacy policies and procedures, systems acquisitions and changes, and extensive training.

  • AFSA Opposes the Sanchez # 808 Amendment.

AFSA has supported members of the military and their families by providing affordable financial services and access to responsible credit products, including vehicle financing and other consumer lending needs, for over 100 years.

Undoubtedly, AFSA supports the desire of servicemembers, their spouses, and all Americans to build credit histories that provide individuals financial choice and the chance of economic mobility. However, this amendment as drafted would restrict servicemembers and their spouses from reaching their full creditworthiness by incorporating unnecessary risk associated with less accurate credit data.

The AFSA team will keep you updated as this year’s NDAA moves through the legislative process.

July 11th, 2022 by