AFSA’s Legal & Regulatory Affairs Department deals with all aspects of the legal environment facing the industry, including legislative issues and regulatory matters. AFSA maintains high-level relationships with regulatory agencies and industry trade groups enabling AFSA staff to provide leadership and expertise to government and consumer advocacy groups (comment letters, amicus briefs, white papers, testimony)
Much of AFSA’s legal and regulatory work is done through the AFSA Law Committee. The Law Committee helps to create and develop AFSA’s judicial, legislative, and regulatory policies and strategies that affect AFSA member companies. Among the benefits of participation in the Law Committee are remaining up-to-date on issues that confront member companies each day, opportunities to network, and the chance to exchange ideas with other in-house counsel in the industry. General counsels or senior attorneys at AFSA Member companies are eligible for membership.
The Law Committee also has six subcommittees: Vehicle Finance, Payment Card, Emerging Issues, Mortgage Lending, Personal Loan and Litigation.
If you are a finance company member interested in learning more about the Law Committee and subcommittees, contact Celia Winslow, Senior Vice President.
Amicus Briefs
Amicus Brief in Ally Financial v. Haskins
September 20, 2020Amicus Briefs
Amicus Brief in CDIA v. Frey
April 27, 2020Amicus Briefs
CDIA v. Frey
April 27, 2020Amicus Briefs
Bank of America Corporation Amicus Brief
January 23, 2020Amicus Briefs
Amicus Brief in Mark R. Thompson, Beth A Thompson v. JPMorgan Chase Bank, N.A.
January 22, 2020Amicus Briefs
First Circuit Order in Thompson v. Chase Withdrawing Opinion & Certifying Question
January 22, 2020Amicus Briefs
First Circuit Order in Thompson v. Chase Withdrawing Opinion & Certifying Question
July 29, 2019Amicus Briefs
Amicus Brief in Rob Miller v. Lobel Financial
April 6, 2019Amicus Briefs
Amicus Brief in Thompson v. JPMorgan Chase Bank
April 5, 2019Amicus Briefs
Amicus Brief in Bobka v. Toyota Motor Credit Corporation
October 29, 2018Amicus Briefs
Supreme Court of Mo. Opinion in Reed v. The Reilly Co.
December 5, 2017Amicus Briefs
Amicus Brief in Hanson v. Santander
March 27, 2017Amicus Briefs
Amicus Brief in Williams v. American Honda Finance Corp.
August 29, 2016Amicus Briefs
City of Miami v. Bank of America and City of Miami v. Wells Fargo
April 7, 2016Amicus Briefs
Amicus Brief in Texas Department of Housing and Community Affairs, et.al., v. The Inclusive Communities Project, Inc.
November 24, 2014Amicus Briefs
Amicus Brief in Larry D. Jesinoski and Cheryle Jesinoski, v. Countrywide Home Loans, Inc., et. al.
September 14, 2014Amicus Briefs
Amicus Brief in Sanchez v. Valencia Holding co., Inc.
March 18, 2014Amicus Briefs
Amiscus Brief in Dana Venneman and Therodore Collins v. BMW finance Services Na, LLC and Financial Services Vehicle Trust
February 2, 2014Amicus Briefs
Amicus Brief in Tiffini Harrelson v. Carmax Auto Superstores California, LLC
October 7, 2013Amicus Briefs
Amicus Brief in Township of Mount Holly, Kathleen Hoffman and Jules Thiessen v. Mt. Holly Gardens Citizens in Action Inc.
September 3, 2013Amicus Briefs
Amicus Brief in Jane B. McInnes v. LPL Financial LLC & Another
March 27, 2013Amicus Briefs
Amicus Brief in American Express Company, et al. v. italian Colors Restaurant
December 28, 2012Amicus Briefs
Amicus Brief in Jesse Meyer , ect. v. Portfolio Recovery Associates, LLC
October 31, 2012Amicus Briefs
Amicus Brief in Stanley Kolbe v. BAC Home Loans Servicing, et al.
October 12, 2012Amicus Briefs
Amicus Brief in Melissa Bediako v. American Honda Finance Corporation
September 28, 2012Amicus Briefs
Amicus Brief in Gil Sanchez v. Valencia Holding Company, LLC
September 1, 2012Amicus Briefs
Amicus Brief in Michael E. Cullen v. State Farm Mutual Automobile Insurance Company
August 17, 2012Amicus Briefs
Amicus Brief in Buzenes v. Nuvell Financial Services, LLC.
March 21, 2012Amicus Briefs
Amicus Brief in Ford Motor Credit Company v. Sudesh Agrawal
March 19, 2012Amicus Briefs
Amicus Brief in Titan Maritime LLC v. Cape Flattery Limited
March 2, 2012Amicus Briefs
Amicus Brief in Tammy Foret Freeman v. Quicken Loans, Inc.
January 10, 2012Amicus Briefs
Amicus Brief in Steve Magner v. Thomas J. Gallagher
December 29, 2011Amicus Briefs
Amicus Brief in Americredit Financial Services Inc. v. Marlene A. Penrod
June 24, 2011Amicus Briefs
Amicus Brief in Ryan C. Henry v. Quicken Loans, Inc
December 12, 2010Amicus Briefs
Amicus Brief in Kim Rivera v. American General Financial Services Inc.
November 12, 2010Amicus Briefs
Amicus Brief in Fisher v. DCH Temecula Imports, LLC
October 12, 2010Amicus Briefs
Amicus Brief in AT&T Mobility LLC v. Vincent and Liza Concepcion
August 9, 2010Amicus Briefs
Amicus Brief in Weinstat v. Dentsply Inernat., Inc.
February 24, 2010Amicus Briefs
Amicus Brief in Aubrey Howard v. AmeriCredit Financial Services, INC
December 3, 2009Amicus Briefs
Amicus Brief in American Express Company v. Italian Colors Restaurant
June 26, 2009Amicus Briefs
Amicus Brief in Nuvell Credit Company LLC v. Toby Rosen
May 20, 2009Amicus Briefs
Amicus Brief in Louis R, Vallies v. Sky Bank
May 5, 2009Amicus Briefs
Amicus Brief in Nuvell Credit Company LLC v. Lisa Renna Callicott
March 12, 2009Amicus Briefs
Amicus Brief in AmeriCredit Financial Services, Inc. v. Marlene A. Penrod
February 6, 2009Amicus Briefs
Amicus Brief in Ford Motor Credit Company, LLC v. Dennis L. and Rebecca J. Mierkowski
January 27, 2009Amicus Briefs
Amicus Brief in Kieth Litman and Robert Wachtel v. Cellco Partnership d/b/a Verizon Wireless
January 7, 2009Amicus Briefs
Amicus Brief in Ford Motor Credit Company, LLC v. Rebecca Ann Dale
December 31, 2008Amicus Briefs
Amicus Brief in American General Financial Services, Inc. v. Shelton Coleman
November 21, 2008Amicus Briefs
Amicus Brief in Wells Fargo Financial Ohio 1, Inc. v. Lillie Alexander
November 21, 2008Amicus Briefs
Amicus Brief in Brack v. Omni Loan Company, Ltd. et al.
September 30, 2008Amicus Briefs
Amicus Brief in John Wesley Ford, Sr. Cynthia Dawn Ford v. Ford Motor Credit Company, LLC
September 30, 2008Amicus Briefs
Amicus Brief in Fremont Investment & Loan v. Fremont General Corporation
September 19, 2008Amicus Briefs
Amicus Brief in Betty E. Vaden v. Discover Bank, et al.
August 8, 2008Amicus Briefs
Amicus Brief in State of Ohio v. Midway Motor Sales, Inc., et al.
July 25, 2008Amicus Briefs
Amicus Brief in State ex Rel. CitiFinancial, Inc. v. John T. Madden
June 11, 2008Amicus Briefs
Amicus Brief in CitiFinancial, Inc. v. Karen Rimmer
June 1, 2008Amicus Briefs
Amicus Brief in American General Financial Services v. Shelton Coleman
May 21, 2008Amicus Briefs
Amicus Brief in Ford Motor Credit Company v. Carl G. Hebert
May 20, 2008Amicus Briefs
Amicus Brief in Wells Fargo Bank, N.A., David A. Hunt, Jr.
April 25, 2008Amicus Briefs
Amicus Brief in Wells Fargo Financial Ohio 1, Inc. v. Charles L. Bluford, et al.
April 17, 2008Amicus Briefs
Amicus Brief in Commonwealth of Massachusetts v. Fremont Investment & Loan, and Fremont General Corporation
March 25, 2008Amicus Briefs
Amicus Brief in AmeriCredit Financial Services v. Eddie M. Tillman
March 17, 2008Amicus Briefs
Amicus Brief in Brett Burgess and Janice M. Burgess v. CitiFinancial Auto
February 22, 2008Amicus Briefs
Amicus Brief in Ford Motor Credit Company v. Sandy Eugene Sanders and Bonnie Jean Chymercy-Sanders
February 6, 2008Amicus Briefs
Amicus Brief in Radian Guaranty, Inc. v. Whitfield, et al.
January 28, 2008Amicus Briefs
Amicus Brief in Tex Star Motors, Inc. v. Regal Finance Company, Ltd, and Regal Finance Company II, Ltd
January 8, 2008Amicus Briefs
Amicus Brief in Brian Dixon v. Shamrock Financial Corporation
December 5, 2007Amicus Briefs
Amicus Brief in Stephen Michael Graupner v. Nuvell Credit Corporation
December 3, 2007Amicus Briefs
Amicus Brief in Sharon Wilborn v. Bank One Corporation
December 3, 2007Amicus Briefs
Amicus Brief in Wells Fargo Financial North Carolina 1, Inc. v. Telephius Letoinne Price and Shawna Denise Price
October 4, 2007Amicus Briefs
Amicus Brief in Aviation Data Inc., et al. v. American Express Travel Related Services Co., Inc., et al.
September 6, 2007Amicus Briefs
Amicus Brief in Darrell Bruce v. Keybank National Association
September 6, 2007Amicus Briefs
Amicus Brief in Juarez v. Arcadia Financial, Ltd.
August 27, 2007Amicus Briefs
Amicus Brief in Stephen Michael Graupner v. Nuvell Credit Corporation
May 30, 2007Amicus Briefs
Amicus Brief in Susan and Bryan Andrews v. Chevy Chase Bank, F.S.B.
April 4, 2007Amicus Briefs
Amicus Brief in Sharon Graham v. Rayon S. Dunkley
March 9, 2007Amicus Briefs
Amicus Brief in Tillman v. Commercial Credit
November 21, 2006Amicus Briefs
Amicus Brief in Safeco Insurance Company of America, et al. v. Charles Burr
November 13, 2006Amicus Briefs
Regulatory Comment Letters
Joint Trade Letter to FCC re: Robocall Reduction
September 8, 2020Regulatory Comment Letter
AFSA Letter to OCC re: National Banks & Federal Savings as Lenders
September 8, 2020Regulatory Comment Letter
AFSA Letter to CFPB re: Time-Barred Debt
August 4, 2020Regulatory Comment Letter
AFSA Comment Letter to CFPB re: LIBOR Transition
August 4, 2020Regulatory Comment Letter
Joint Trades Letter to FCC re: Safe Harbor for Voice Service Providers
July 2, 2020Regulatory Comment Letter
AFSA Comment Letter to FDIC re: Industrial Banks and Industrial Loan Companies
July 1, 2020Regulatory Comment Letter
AFSA Letter to FTC re: Endorsement Guides
June 22, 2020Regulatory Comment Letter
AFSA Letter to CFPB re: Taskforce on Federal Consumer Financial Law
June 2, 2020Regulatory Comment Letter
Joint Trade Letter to FCC re: Reply Comment on Petitition for Expedited Ruling
May 21, 2020Regulatory Comment Letter
AFSA Comment Letter to FCC re: STIR/SHAKEN
May 15, 2020Regulatory Comment Letter
AFSA Letter to Federal Reserve Bank of Boston re: Main Street Lending Program
May 6, 2020Regulatory Comment Letter
AFSA Letter to FCC re: Petition for Expedited Declaratory Ruling, Clarification, or Waiver
April 21, 2020Regulatory Comment Letter
AFSA Letter to Fed Chair Powell re: Federal Reserve Funding Facilities
April 16, 2020Regulatory Comment Letter
AFSA Comment Letter to SBA re: Business Loan Program Temporary Changes; Paycheck Protection Program
April 8, 2020Regulatory Comment Letter
Joint Trade Letter to Fed Chair Powell and Secretary Mnunchin re: Expansion of Commercial Paper Funding Facility
March 31, 2020Regulatory Comment Letter
AFSA Letter to Federal Reserve Bank of New York re: Expansion of Commercial Paper Funding Facility
March 31, 2020Regulatory Comment Letter
AFSA Comment Letter to 309 re: Small Business Lending under the CARES Act
March 31, 2020Regulatory Comment Letter
Joint Trade Letter to SEC re: Uniform CECL Implementation
March 31, 2020Regulatory Comment Letter
Joint Trade Letter to FCCre: Petition for Expedited Ruling for Calls & Texts during Pandemic
March 30, 2020Regulatory Comment Letter
Joint Trade Letter to SECre: Delaying Implementation ofCECL Requirements
March 22, 2020Regulatory Comment Letter
AFSA Comment Letterto FCC re: Reassigned Numbers Database
March 12, 2020Regulatory Comment Letter
AFSA Comments on Call Blocking
February 28, 2020Regulatory Comment Letter
AFSA letter to fCCex parte presentation; cg docket nos. 02-278, 18-152
February 5, 2020Regulatory Comment Letter
AFSA letter to fDICre: permissible interest
February 4, 2020Regulatory Comment Letter
AFSA letter to fTCre: accuracy in consumer reporting workshop
February 1, 2020Regulatory Comment Letter
AFSA letter to oCCre: permissible interest
January 21, 2020Regulatory Comment Letter
joint trade letter to cFPBre: tRIDassessment
January 21, 2020Regulatory Comment Letter
petition for declaratory ruling filed by capital one services, l
December 23, 2019Regulatory Comment Letter
AFSA letter to cFPBre: tech sprints
November 8, 2019Regulatory Comment Letter
AFSA letter to nHTSAre: e-titling
October 28, 2019Regulatory Comment Letter
AFSA letter to hUDre: disparate impact rule
October 18, 2019Regulatory Comment Letter
letter to cFPBcommenting on data points by the home mortgage disclosure act
October 15, 2019Regulatory Comment Letter
AFSA letter to cFPBre: proposed debt collection rule
September 18, 2019Regulatory Comment Letter
letter to fCCre: robocalls
August 2, 2019Regulatory Comment Letter
letter to fTCre: safeguards rule
August 2, 2019Regulatory Comment Letter
letter to fCCre: robocalls
July 25, 2019Regulatory Comment Letter
letter to fTCre: data privacy
June 30, 2019Regulatory Comment Letter
letter to fCCchairman pai regarding robocalls
June 18, 2019Regulatory Comment Letter
letter to oMBre: cFPBdiversity & inclusion form
May 23, 2019Regulatory Comment Letter
letter to cFPBon proposed payday rule
May 15, 2019Regulatory Comment Letter
AFSA letter to cFPBre: rFIon credit card market
May 1, 2019Regulatory Comment Letter
AFSA letter to cFPBre: debt collections survey
March 6, 2019Regulatory Comment Letter
AFSA letter to fDICre: industrial bank application process r
February 11, 2019Regulatory Comment Letter
AFSA letter to fTCre: identity theft rules
February 11, 2019Regulatory Comment Letter
AFSA letter to cFPBre: no action letters
February 11, 2019Regulatory Comment Letter
AFSA letter to fDICre: small-dollar lending r
January 21, 2019Regulatory Comment Letter
AFSA letter to fTCre: military credit monitoring rulemaking
January 8, 2019Regulatory Comment Letter
AFSA letter to fASBre: measurement of credit losses on financial instruments
November 5, 2018Regulatory Comment Letter
AFSA letter to iRSre: proposed regulations under section 199
October 1, 2018Regulatory Comment Letter
AFSA letter to fTCre: 21st century hearings
August 19, 2018Regulatory Comment Letter
AFSA letter to hUDre: amendment of fair housing act
August 17, 2018Regulatory Comment Letter
AFSA letter to fCCre: advanced methods to target & eliminate unlawful robocalls
August 16, 2018Regulatory Comment Letter
AFSA- rFIon complaint processes
July 16, 2018Regulatory Comment Letter
AFSA- rFIon financial education
July 11, 2018Regulatory Comment Letter
AFSA- rFIon complaint reporting
July 2, 2018Regulatory Comment Letter
AFSA- rFIonguidance
July 2, 2018Regulatory Comment Letter
AFSA- rFIon inherited rules
June 25, 2018Regulatory Comment Letter
AFSA- rFIon adopted rules
June 19, 2018Regulatory Comment Letter
AFSA Comment letter to fCCadvocating changes to tCPAregulations
June 13, 2018Regulatory Comment Letter
AFSA- rFIon rulemaking process (docket no. cFPB-2018-0009)
June 8, 2018Regulatory Comment Letter
Advanced methods to target and eliminate unlawful robocalls, second further notice of proposed rulemaking (cg docket no. 17-59)
June 8, 2018Regulatory Comment Letter
AFSA- rFIexternal engagements
May 29, 2018Regulatory Comment Letter
AFSA letter to cFPBre: rFIon supervision program
May 21, 2018Regulatory Comment Letter
AFSA RFIenforcement final [docket no. bureau- 2018-0003]
May 14, 2018Regulatory Comment Letter
AFSA letter to cFPBre: rFIon bureau rules of practice for adjudication proceedings
May 7, 2018Regulatory Comment Letter
petition for declaratory ruling before the fCCre: the tcpa
May 5, 2018Regulatory Comment Letter
regarding bureau civil investigative demands and associated processes [docket no. bureau- 2018-0001]
April 26, 2018Regulatory Comment Letter
letter from nADAand AFSAon doDmilitary lending act interpretive rule
January 18, 2018Regulatory Comment Letter
AFSA letter to cFPBre: consumer complaint database
December 28, 2017Regulatory Comment Letter
Letter Urging House Passage of H.R. 2396 Privacy Notification Technical Clarification Act
December 11, 2017Regulatory Comment Letter
Letter of Support for Senate FY18 Appropriations Package CFPB Provisions
November 27, 2017Regulatory Comment Letter
Letter Commending H.R. 2396 Privacy Notification Technical Clarification Act
October 10, 2017Regulatory Comment Letter
AFSA letter to cFPBre: rFIon small business lending market
September 14, 2017Regulatory Comment Letter
AFSA letter to fCCsupporting effort on reassigned numbers
August 28, 2017Regulatory Comment Letter
AFSA letter to fCCre: call authentication trust anchor
August 14, 2017Regulatory Comment Letter
Joint Trade Letter Urging Approval of Resolutions Overturning CFPB Arbitration Rule
August 1, 2017Regulatory Comment Letter
AFSAreply comment to fCCre: advanced methods to target and eliminate unlawful robocalls
July 31, 2017Regulatory Comment Letter
AFSA Comment letter on executive order 13772, core principles for regulating the us financial system
July 19, 2017Regulatory Comment Letter
Letter Supporting FCRA Harmonization Act
July 11, 2017Regulatory Comment Letter
Letter Supporting Privacy Notice, Regulatory Examination, and Debt Collection Regulatory Reform Proposals
July 10, 2017Regulatory Comment Letter
Letter of the Record Supporting House FY18 Financial Services Appropriations Legislation
July 6, 2017Regulatory Comment Letter
AFSA letter supporting the fCCproposed rule re: illegal robocalls
July 3, 2017Regulatory Comment Letter
joint coalition letter requesting meeting with attorney general
June 30, 2017Regulatory Comment Letter
joint trade letter seeks mLAchanges from do
June 23, 2017Regulatory Comment Letter
Coalition Letter Commending Subcommittee on Constitution and Civil Justice on Hearing re: TCPA
June 12, 2017Regulatory Comment Letter
AFSA letter commenting on cFPBrequest for information re: consumer credit marketplace
June 8, 2017Regulatory Comment Letter
Testimony Urging CFPB Reform in Senate FY18 Appropriations Legislation
May 24, 2017Regulatory Comment Letter
joint trade letter commenting on CFPB RFIre: the small business lending market (may 23, 2017)
May 23, 2017Regulatory Comment Letter
letter supporting declaratory ruling in all about the message
May 18, 2017Regulatory Comment Letter
AFSA Letter Supporting Financial CHOICE Act of 2017
May 1, 2017Regulatory Comment Letter
Letter to the Senate Banking Committee Responding to a Request for Proposals to Foster Economic Growth
April 14, 2017Regulatory Comment Letter
Letter Supporting Amendment to CHOICE 2.0 re: APR Calculation Prohibitions
March 29, 2017Regulatory Comment Letter
Letter for the Record on Committee Hearing: Ending the De Novo Drought: Examining the Application Process for De Novo Financial Institutions
March 20, 2017Regulatory Comment Letter
Letter for the Record Supporting CFPB Reform
March 20, 2017Regulatory Comment Letter
joint trade letter re: tCPAexpress consent
March 10, 2017Regulatory Comment Letter
Coalition Letter to House E&C Supporting HR 985
March 8, 2017Regulatory Comment Letter
Coalition Letter to House Supporting H.R. 985 FICALA
March 8, 2017Regulatory Comment Letter
AFSA letter commenting on advanced notice of proposed rulemaking re: enhanced cyber security management standards
February 16, 2017Regulatory Comment Letter
AFSA letter supporting petition for reconsideration by navient corp.
February 13, 2017Regulatory Comment Letter
Joint Letter Supporting the Regulatory Accountability Act of 2017
February 6, 2017Regulatory Comment Letter
AFSA letter commenting on safeguard rules
November 21, 2016Regulatory Comment Letter
AFSA letter responding to cFPBrequest for information; notice of proposed rule on payday, vehicle title, and certain high-cost installment loans
November 7, 2016Regulatory Comment Letter
AFSA letter commenting on request for information on payday loans, vehicle title loans, installment loans, and open-end lines of credit
November 7, 2016Regulatory Comment Letter
Amendments Relating to Disclosure of Records & Information Docket No. Bureau-2016-0039; RIN 3170-AA63
October 24, 2016Regulatory Comment Letter
AFSA letter commenting on the proposed rule on payday, vehicle title, and certain high-cost installment loans
October 6, 2016Regulatory Comment Letter
AFSA letter commenting on interpretive rule – military lending act limitations on terms of consumer credit extended to service members and dependents
September 22, 2016Regulatory Comment Letter
AFSA Letter Supporting Financial CHOICE Act of 2016
September 12, 2016Regulatory Comment Letter
AFSA letter commenting on the proposed rule on arbitration agreements
August 22, 2016Regulatory Comment Letter
AFSA letter commenting on the proposed rule on annual privacy notices
August 10, 2016Regulatory Comment Letter
Joint Letter Supporting S. 2663, Reforming CFPB Indirect Auto Financing Guidance Act
July 19, 2016Regulatory Comment Letter
AFSA Statement for the Record in Support of New Industrial Bank Charters
July 13, 2016Regulatory Comment Letter
AFSA letter commenting on uniform interagency consumer compliance rating system
July 5, 2016Regulatory Comment Letter
AFSA Letter Supporting H.R. 5485, Financial Services and General Government Appropriations Act, 2017
June 23, 2016Regulatory Comment Letter
AFSA letter to the fCCon proposed rulemaking regarding the telephone consumer protection act
June 6, 2016Regulatory Comment Letter
Joint Letter Supporting H.R. 1486, Taking Account of Bureaucrats' Spending TABS Act
April 15, 2016Regulatory Comment Letter
joint trade letter to the dod with recommended clarifications and modifications to the military lending act rule
April 7, 2016Regulatory Comment Letter
AFSA letter to the doDand the interagency working group with clarifications to the military lending act rule
April 7, 2016Regulatory Comment Letter
AFSA Letter to the Senate Banking, Housing and Urban Affairs Committee Chairman and Ranking Member in advance of the CFPB's Semi-Annual Report to Congress
April 5, 2016Regulatory Comment Letter
AFSA/cBAcomment letter on fTCauto survey
March 7, 2016Regulatory Comment Letter
AFSA Comment letter on "holder rule"
February 12, 2016Regulatory Comment Letter
AFSA Comment letter seeking vendor access to dMDCdatabase
February 10, 2016Regulatory Comment Letter
AFSA Letter Supporting H.R. 766, Financial Institutions Consumer Protection Act of 2015
February 3, 2016Regulatory Comment Letter
Joint Trade Letter Seeking Extension of DMDC Registration Deadline
January 26, 2016Regulatory Comment Letter
joint trade letter on the proposed collection of information relating to the national survey of existing mortgage borrowers (nSEMB)
January 11, 2016Regulatory Comment Letter
Coalition Letter in Support of H.R. 1927, Fairness in Class Action Litigation Act of 2015
January 6, 2016Regulatory Comment Letter
Joint Trade Letter in Support of H.R. 1737, Reforming CFPB Indirect Auto Financing Guidance Act
November 18, 2015Regulatory Comment Letter
AFSA Comment letter to the office of inspector general (oIG) of the federal reserve system regarding the oIGwork plan
September 16, 2015Regulatory Comment Letter
AFSA Comment letter to the office of the executive secretary of the consumer financial protection bureau regarding the consumer complaint database & data normalization
August 31, 2015Regulatory Comment Letter
memo of ex parte communication with mortgage servicer working group and the consumer financial protection bureau
July 20, 2015Regulatory Comment Letter
AFSA Comment letter to the office of the executive secretary of the consumer financial protection bureau regarding the credit card market
June 17, 2015Regulatory Comment Letter
Joint Trade Letter in Support of H.R. 1737, Reforming CFPB Indirect Auto Financing Guidance Act
June 10, 2015Regulatory Comment Letter
AFSA Comment letter on consumer complaint intake system company portal boarding form information collection system
June 8, 2015Regulatory Comment Letter
AFSA letter commenting on request for information regarding the consumer complaint database docket
May 26, 2015Regulatory Comment Letter
AFSA letter commenting on cFPB's arbitration study
May 21, 2015Regulatory Comment Letter
AFSA letter commenting on request for information regarding credit card market
May 18, 2015Regulatory Comment Letter
AFSA Letter Urging Changes to DoD Military Lending Act Rule
May 14, 2015Regulatory Comment Letter
AFSA letter commenting on limitations on terms of consumer credit extended to service members and dependents
May 11, 2015Regulatory Comment Letter
AFSA letter commenting on consumer complaint narrative
April 30, 2015Regulatory Comment Letter
AFSA letter commenting on cFPB's process for determining whether to utilize its authority under dodd-frank section 1028(b) to regulate arbitration
April 29, 2015Regulatory Comment Letter
AFSA Testimony on Regulatory Burdens on Non-Depository Financial Institutions
April 15, 2015Regulatory Comment Letter
Joint Trade Letter in Support of the Eliminate Privacy Notice Confusion Act
March 23, 2015Regulatory Comment Letter
AFSA letter commenting on petition for exemption filed by citizens bank concerning prior express consent under the telephone consumer protection act
March 16, 2015Regulatory Comment Letter
AFSA letter commenting on proposed amendments to mortgage servicing regulations
March 16, 2015Regulatory Comment Letter
Joint Trade Letter on Finance Product Safety Commission Act
March 4, 2015Regulatory Comment Letter
Joint Trade Letter to CFPB on Vehicle Finance Study
February 18, 2015Regulatory Comment Letter
AFSA letter commenting on cFPB's consumer complaint intake system company portal boarding form information collection system
February 2, 2015Regulatory Comment Letter
AFSA Comment letter on limitations on terms of consumer credit extended to service members and dependents
December 22, 2014Regulatory Comment Letter
AFSA Comment letter on policy on no-action letters
December 15, 2014Regulatory Comment Letter
AFSA Comment letter on defining larger participants of the automobile financing market and defining certain automobile leasing activity as a financial product or service
December 8, 2014Regulatory Comment Letter
AFSA Comment letter on study of pre-dispute arbitration mandated by dodd-frank act § 1028(a)
December 4, 2014Regulatory Comment Letter
AFSA Comment letter on petition for declaratory ruling from consumer bankers association
November 17, 2014Regulatory Comment Letter
AFSA Comment letter on home mortgage disclosure (regulation c)
October 28, 2014Regulatory Comment Letter
AFSA Comment letter on disclosure of consumer complaint narrative data
September 22, 2014Regulatory Comment Letter
AFSA Comment letter on tILA/rESPAintegrated mortgage disclosures rules
September 16, 2014Regulatory Comment Letter
Letter to Congress from the Consumer Credit Industry on Vehicle Finance
September 8, 2014Regulatory Comment Letter
AFSA Comment letter on petition for expedited declaratory ruling filed by santander consumer usa, inc.
September 2, 2014Regulatory Comment Letter
AFSA Comment letter on debt collection survey from the consumer credit panel
August 22, 2014Regulatory Comment Letter
AFSA Comment letter on petition for expedited declaratory ruling filed by stage sores, inc.
August 8, 2014Regulatory Comment Letter
AFSA Letter Supporting the End Operation Choke Point Act of 2014
July 24, 2014Regulatory Comment Letter
AFSA Statement of Support for Examination and Supervisory Privilege Parity Act
July 15, 2014Regulatory Comment Letter
AFSA Comment letter on amendment to the annual privacy notice requirement under the gramm-leach-bliley act
July 14, 2014Regulatory Comment Letter
AFSA Comment letter on telephone survey exploring awareness of and perceptions regarding dispute resolution provisions in credit card agreements
June 30, 2014Regulatory Comment Letter
Joint Trade Letter Supporting the Bureau Guidance Transparency Act
June 10, 2014Regulatory Comment Letter
Joint Trade Letter Supporting the Disparate Impact Amendment to Appropriations Bill
May 29, 2014Regulatory Comment Letter
AFSA Comment letter on fHA; handling prepayments; eliminating post-payment interest charges
May 12, 2014Regulatory Comment Letter
AFSA Comment letter on HMDA.
May 12, 2014Regulatory Comment Letter
Joint Trade Letter to Senate Banking Committee on housing Finance Reform
May 1, 2014Regulatory Comment Letter
AFSA Letter to Senators on Traditional Installment Loans
March 31, 2014Regulatory Comment Letter
AFSA Comment letter on re-opening of comment period for asset-backed securities release
March 28, 2014Regulatory Comment Letter
AFSA Comment letter on petition for rulemaking of aCAinternational
March 24, 2014Regulatory Comment Letter
AFSA Comment letter on petition for expedited declaratory ruling from united healthcare services, inc.
March 10, 2014Regulatory Comment Letter
AFSA Files Freedom of Information Act FOIA Request for CFPB Disparate Impact Methodology
March 10, 2014Regulatory Comment Letter
AFSA Comment letter on debt collection, docket no cFPB-2013-0033
February 28, 2014Regulatory Comment Letter
AFSA Comment letter on petition for declaratory ruling filed by the retail industry leaders association
February 21, 2014Regulatory Comment Letter
AFSA Comment letter on cFPB's request for information regarding the mortgage closing process.
February 7, 2014Regulatory Comment Letter
AFSA Comment letter on petition for declaratory ruling filed by glide talk, ltd.
January 3, 2014Regulatory Comment Letter
AFSA Letter to FCC re: Professional Association for Customer Engagement’s Petition for Expedited Declaratory Ruling and/or Expedited Rulemaking
December 19, 2013Regulatory Comment Letter
AFSA Letter to FCC re: Petition for Declaratory Ruling filed by a Coalition of Mobile Engagement Providers
December 2, 2013Regulatory Comment Letter
AFSA Testimony on Soldiers as Consumers
November 20, 2013Regulatory Comment Letter
AFSA Comment Letter to Federal Agencies re: Credit Risk Retention
October 30, 2013Regulatory Comment Letter
Joint Trade Letter on Privacy Notice Modernization Act
October 29, 2013Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Company Portal Services Agreement
October 16, 2013Regulatory Comment Letter
AFSA and Consumer Mortgage Coalition Joint Trade Letter to GAO re: CFPB’s Complaint Database Lacks Consumer Privacy Protections
September 4, 2013Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Telephone Survey Exploring Consumer Awareness of and Perceptions Regarding Dispute Resolution Provisions in Credit Card Agreements
August 6, 2013Regulatory Comment Letter
AFSA Comment Letter to Federal Docket Management System Office re: Limitations on Terms of Consumer Credit Extended to Service Members and Dependents
August 1, 2013Regulatory Comment Letter
AFSA Comment Letter to FCC re: Petition for Declaratory Ruling filed by YouMail, Inc.
July 19, 2013Regulatory Comment Letter
AFSA Comment Letter to Board of Governors of the Federal Reserve System re: Section 318 of Dodd-Frank Act
June 14, 2013Regulatory Comment Letter
Joint Trades Letter to HUD and CFPB re: Request for Guidance and Clarity on Disparate Impact and Dodd-Frank Mortgage Standards
June 4, 2013Regulatory Comment Letter
AFSA Comment Letter to FHFA re: Lender Placed Insurance, Terms and Conditions
May 28, 2013Regulatory Comment Letter
AFSA Comment Letter to CFPB Ombudsman re: Timeframe for Comment Letters and Up-to-date Information from CFPB
March 20, 2013Regulatory Comment Letter
AFSA Letter to CFPB re: Request for Information Regarding Financial Products Marketed to Students Enrolled in Institutions of Higher Education
March 18, 2013Regulatory Comment Letter
Joint Trade Letter Urging Use of QM Standards when Defining QRM
March 4, 2013Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Request For Information Regarding Credit Card Market
February 19, 2013Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Credit Card Ability-to-Pay Requirements
January 7, 2013Regulatory Comment Letter
Joint Trade Letter on Mortgage Forgiveness Debt Relief Act
December 12, 2012Regulatory Comment Letter
AFSA Comment Letter to FCC re: Petition for Declaratory Ruling filed by Communication Innovators
November 15, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Mortgage Discosures under RESPA and TILA
November 6, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Proposed Mortgage Servicing Rules to Amend Regulation Z and Regulation X
October 9, 2012Regulatory Comment Letter
AFSA Comment Letter to Treasury re: Interim Final Rule to Establish Assessments to Fund OFR and Financial Research Fund
September 17, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: HOEPA and Finance Charges
September 7, 2012Regulatory Comment Letter
Joint Trade Letter on Small Business Provisions in Dodd-Frank Act
August 1, 2012Regulatory Comment Letter
AFSA Letter to FSOC re: Hearing Procedures for Proceedings Under Title I or Title VIII of the Dodd-Frank Wall Street Reform and Consumer Protection Act
July 30, 2012Regulatory Comment Letter
Joint Trade Letter to House Financial Services Committee on Privilege Bill
July 25, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Disclosure of Consumer Complaint Data
July 19, 2012Regulatory Comment Letter
Joint Trades Letter to CFPB re: Outine of Servicing Rules Under Consideration
July 11, 2012Regulatory Comment Letter
AFSA Statement to Senate Banking Committee on Military Lending
June 26, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Pre-Dispute Arbitration Agreements
June 22, 2012Regulatory Comment Letter
AFSA Statement to the House Financial Services Committee on Mortgage Disclosures
June 20, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Regulation Z
June 8, 2012Regulatory Comment Letter
AFSA CommentLetter to CFPB re: Streamlining Inherited Regulations- Response to Comments Filed
June 4, 2012Regulatory Comment Letter
AFSA Letter to House Committee on Oversight and Government Reform
June 1, 2012Regulatory Comment Letter
AFSA Letter to Board of Governors of Federal Reserve System re: Regulation YY – Enhanced Prudential Standards
April 30, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Defining Larger Participants in Certain Consumer Financial Product and Service Markets
April 17, 2012Regulatory Comment Letter
Joint Trade letter to CFPB on QM
April 16, 2012Regulatory Comment Letter
Joint Trade Letter on Student Loans and Bankruptcy
March 20, 2012Regulatory Comment Letter
Joint Trade Letter to CFPB on Privileged Information
March 7, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Streamlining Inherited Regulations
March 5, 2012Regulatory Comment Letter
AFSA Comment Letter to Treasury re: Proposed Rule to Establish Assessments to Fund OFR and Financial Research Fund
March 5, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Final Interim Rules for Regulation Z and Regulation V
February 21, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Credit Card Agreement Prototype
February 16, 2012Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Disclosure of Certain Credit Card Complaint Data
January 30, 2012Regulatory Comment Letter
AFSA Letter to CFPB Re: Generic Clearance for Consumer Complaint and Information Collection Systems
December 23, 2011Regulatory Comment Letter
AFSA and NAIB Letter to FSOC Re: Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies
December 19, 2011Regulatory Comment Letter
AFSA Letter to CFPB Re: Mortgage Disclosure Team Prototype Designs for Settlement Disclosure Form
November 16, 2011Regulatory Comment Letter
Joint Trade Letter to Congress on Deficit Reduction
September 29, 2011Regulatory Comment Letter
AFSA Comment Letter to CFPB Re: Disclosure Notice, State Officials Notice, Adjudication Notice, and Investigations Notice
September 26, 2011Regulatory Comment Letter
Joint Trade Letter to Congress in Support of Retaining Graves Law
September 7, 2011Regulatory Comment Letter
AFSA Letter to Federal Agencies Re: Credit Risk Retention
August 1, 2011Regulatory Comment Letter
AFSA Letter in Support of H.R. 1121, The Responsible Consumer Financial Protection Regulations Act of 2011
May 3, 2011Regulatory Comment Letter
AFSA Letter in Support of H.R. 1667, Consumer Financial Protection Transfer Clarification Act
May 3, 2011Regulatory Comment Letter
AFSA Letter in Support of H.R. 1315, The Consumer Financial Protection Safety and Soundness Improvement Act
May 3, 2011Regulatory Comment Letter
AFSA Letter Supporting the Business Activity Tax Simplification Act
April 13, 2011Regulatory Comment Letter
Joint Trade Letter on Housing Finance System
March 29, 2011Regulatory Comment Letter
AFSA Letter to FTC Re: Motor Vehicle Roundtables
March 28, 2011Regulatory Comment Letter
AFSA Letter to Federal Reserve Board of Governors Re: Interim Mortgage Disclosure Improvement Act Rule to Clarify Certain Provisions of the September 2010 Interim Rule
February 28, 2011Regulatory Comment Letter
AFSA Letter to FSOC Re: Notice of Proposed Rulemaking Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies
February 25, 2011Regulatory Comment Letter
Joint Trades Letter to Federal Reserve Board of Governors Re: Proposed Rule on Debit Card Interchange Fees
February 22, 2011Regulatory Comment Letter
AFSA Comment Letter to Federal Reserve Board of Governors Re: Debit Card Interchange Fees and Routing
February 22, 2011Regulatory Comment Letter
AFSA and MBA Letter to CFPB re: Consumer Inquiry and Complaint Database
February 9, 2011Regulatory Comment Letter
AFSA Comment letter on docket no. 9-1390 (credit protection products)
December 23, 2010Regulatory Comment Letter
AFSA Comment letter on regulation z interim final rule, valuation independence
December 21, 2010Regulatory Comment Letter
AFSA Comment letter on exposure draft: leases and exposure draft
December 8, 2010Regulatory Comment Letter
AFSA Comment letter on interim rule revising disclosure requirements for closed-end mortgages
November 23, 2010Regulatory Comment Letter
AFSA Comment letter on mortgage acts and practices – advertising rulemaking
November 15, 2010Regulatory Comment Letter
AFSA Comment letter on rESPAand tILAdisclosures
November 10, 2010Regulatory Comment Letter
AFSA Comment letter on advance notice of proposed rulemaking regarding authority to require supervision and regulation of certain nonbank financial companies
November 5, 2010Regulatory Comment Letter
AFSA Comment letter on lease accounting project
October 21, 2010Regulatory Comment Letter
AFSA Comment letter on proposed rules of practice and procedure
October 12, 2010Regulatory Comment Letter
AFSA Comment letter on interim final regulation on appraiser independence
September 28, 2010Regulatory Comment Letter
AFSA Comment letter on fACTAnotices, summary of rights and notice of duties under the fair credit reporting act
September 21, 2010Regulatory Comment Letter
AFSA Comment letter on proposed accounting standard update, "disclosure of certain loss contingencies"
September 20, 2010Regulatory Comment Letter
AFSA Comment letter on implementation period for interim final regulation
September 13, 2010Regulatory Comment Letter
AFSA Comment letter on home mortgage disclosure act request for comment
August 20, 2010Regulatory Comment Letter
AFSA Comment letter on asset-backed securities proposed rule
August 2, 2010Regulatory Comment Letter
Joint Trade Letter Supporting H.R. 1020 and H.R. 1237 Preserving Arbitration
June 30, 2010Regulatory Comment Letter
Joint Trade Letter Opposing FTC Expansion
June 10, 2010Regulatory Comment Letter
AFSA Comment letter on notice of proposed rulemaking – telephone consumer protection act
May 21, 2010Regulatory Comment Letter
AFSA Comment letter on docket no. r-1384
April 14, 2010Regulatory Comment Letter
AFSA Comment letter on mortgage assistance relief services rulemaking
March 29, 2010Regulatory Comment Letter
Multi-Industry Consumer Financial Protection Agency Letter to Senators Dodd and Shelby
February 17, 2010Regulatory Comment Letter
AFSA Comment letter on proposed revisions to bankruptcy rule 3001
February 16, 2010Regulatory Comment Letter
AFSA Comment letter on information reporting for payments made in settlement of payment card and third party network transactions
January 25, 2010Regulatory Comment Letter
AFSA Comment letter on proposed changes to closed-end mortgage rules
December 23, 2009Regulatory Comment Letter
AFSA Comment letter on proposed changes to home equity lines of credit rules
December 23, 2009Regulatory Comment Letter
AFSA Comment letter on regulation z
November 20, 2009Regulatory Comment Letter
AFSA Comment letter on telemarketing sales rules – debt relief amendments
October 9, 2009Regulatory Comment Letter
AFSA Comment letter on interim final rule for the credit card accountability responsibility and disclosure act of 2009
September 21, 2009Regulatory Comment Letter
AFSA Comment letter on mortgage acts and practices rulemaking
July 30, 2009Regulatory Comment Letter
AFSA Comment letter on consumer assistance to recycle and save act of 2009
July 16, 2009Regulatory Comment Letter
AFSA Comment letter on mortgage assistance relief services rulemaking
July 15, 2009Regulatory Comment Letter
AFSA Comment letter on proposed rule concerning registration of mortgage loan originators
July 9, 2009Regulatory Comment Letter
AFSA Comment letter on proposed rule relating to clarifications of regulations addressing unfair credit card practices
June 4, 2009Regulatory Comment Letter
AFSA Comment letter on paul d. s. edward's petition for an expedited clarification and declaratory ruling concerning the telephone consumer protection act rules
April 2, 2009Regulatory Comment Letter