American Financial Services Association - AFSA Submits Comment Letter to OCC on Fair Access to Financial Services Proposed Rule
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AFSA Submits Comment Letter to OCC on Fair Access to Financial Services Proposed Rule

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On January 4, 2021, AFSA submitted a comment letter to the Office of the Comptroller of the Currency (OCC) regarding its proposed rule on Fair Access to Financial Services.  This proposal reiterates that banks operating under the OCC’s governance should offer financial products and services to customers based on individualized risk assessments rather than based on whether the customer falls in particular category of customers.  The proposed rule is specifically aimed at preventing banks from denying services to customers based on the banks’ preference to avoid offering services to customers engaged in controversial industries.

The AFSA comment letter applauds the OCC for working to support fair access to financial services unimpeded by political or other biases.  There may be some instances, however, when a bank should be allowed to make a quicker determination about the products or services it can offer a customer based on the customer’s business.  AFSA encouraged the OCC to consider whether an entirely new risk assessment is necessary for each new customer, or whether a bank can be allowed to decline services to customers whose characteristics are outside the bank’s risk tolerance based on an abbreviated review.  The comment letter also seek clarification on the proposed rule’s reference to providing financial services on “proportionally equal terms.”  This proposal will hopefully help financial institutions serve customers with greater clarity and objectivity.

AFSA Submits Comment Letter to OCC on Fair Access to Financial Services Proposed Rule
Jan 04, 2021

On January 4, 2021, AFSA submitted a comment letter to the Office of the Comptroller of the Currency (OCC) regarding its proposed rule on Fair Access to Financial Services.  This proposal reiterates that banks operating under the OCC’s governance… Read the rest

January Business Partner Spotlight: GOLDPoint Systems
Jan 04, 2021

The featured Business Partner for January is GOLDPoint Systems which offers one of the most complete Loan Management Software Systems in the Direct and Indirect market, covering the complete loan life cycle. GOLDPoint products include… Read the rest

Happy New Year!
Jan 01, 2021

From everyone at AFSA, we wish you and your loved ones have a safe and happy New Year!… Read the rest

LISTEN | Closing 2020 with AFSA President & CEO Bill Himpler
Dec 29, 2020


In this episode of the AFSA Extra Credit Podcast, we close out the year with AFSA President & CEO Bill Himpler. We discuss many of the successes the association has seen in 2020 and outline some goals to work for in 2021. Bill also highlights
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Focus on Innovation with Keynoter Peter Diamandis, sponsored by FIS
Dec 22, 2020

Keynote sponsored by

The American Financial Services Association is pleased to announce that Peter Diamandis, Co-Founder & Executive Chairman of the XPrize Foundation, and one of the most dynamic speakers in the tech industry, will… Read the rest

AFSA Outlines 2021 Federal Priorities
Dec 22, 2020

The American Financial Services Association (AFSA) recently released its 2021 Federal Priorities. America has a full history of evolving national consumer financial protection laws aimed at ensuring consumers are fairly and responsibly… Read the rest

Disregard non-AFSA Solicitations
Dec 22, 2020

AFSA is aware of several scam companies and individuals posing as AFSA staff members offering a variety of professional contact lists. Many of the most recent messages offer discounted contact lists for upcoming conferences.

YouRead the rest

Mass. High Court Issues Opinion in State-mandated Default Notice Case
Dec 18, 2020

AFSA is sharing the below case summary with members with permission from K&L Gates. The original can be found here. AFSA signed onto a joint amicus brief in this case available here.


 THE MASSACHUSETTS SUPREME JUDICIAL COURT HOLDS STATE-MANDATEDRead the rest

FDIC Finalizes ILC Rules
Dec 18, 2020

This week, the FDIC finalized a rule to require certain conditions and commitments for each deposit insurance application approval from an industrial bank or industrial loan company (ILC) whose parent company is not subject to consolidated… Read the rest

AFSA Supports Remote Online Notarizations
Dec 17, 2020

Today the American Financial Services Association (AFSA) joined several other financial services trade associations and organizations in a letter urging Congressional leaders to include the bipartisan Securing and Enabling CommerceRead the rest

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