Comment Letters

November 4, 2016 | Filed under: Other Areas of Interest | Tagged with: Congress, Funding

NACA joins 200+ organizations on letter to Congress urging opposition to FY 2017 omnibus or minibus funding packages that include harmful ideological policy riders. Budget bills have been used before to undermine essential safeguards through policy riders – provisions that address extraneous policy issues, and are slipped into funding bills to win approval as part of must-pass funding legislation. 

October 27, 2016 | Filed under: Other Areas of Interest | Tagged with: FDIC, Preemption

NACA joins other national and state consumer, legal services and civil rights groups on comments on the FDIC’s proposed Third-Party Lending Guidance (Third-Party Guidance). The groups "strongly oppose any suggestion in the guidance that it is ever appropriate for a bank to rent out its charter in a way that will allow the third party to evade state laws." 

October 17, 2016 | Filed under: Other Areas of Interest | Tagged with: FCC

NACA joins groups on a letter to the Federal Communications Commission regarding pending actions to protect consumers in the digital age. 

September 14, 2016 | Filed under: Other Areas of Interest | Tagged with: Regulations

NACA joined other consumer, small business, labor, good government, financial protection, community, health, environmental, civil rights and public interest groups in strongly opposing H.R. 5226, the Regulatory Integrity Act. The Regulatory Integrity Act would significantly undermine federal agencies’ ability to engage and inform the public in a meaningful and transparent way regarding its work on important science-based rulemakings that will greatly benefit the public. As a result, the bill will lead to decreased public awareness and participation in the rulemaking process in direct contradiction of the Administrative Procedure Act and agencies’ authorizing statutes, which specifically provide for broad stakeholder engagement.

September 13, 2016 | Filed under: Other Areas of Interest | Tagged with: CFPB

NACA joined consumer, fair lending, community and privacy organizations in a letter to U.S. House Financial Services Committee to express strong opposition to provisions in the Financial CHOICE Act (H.R. 5983) that would severely undermine the effectiveness of the Consumer Financial Protection Bureau’s (CFPB) consumer complaint database. The groups
also oppose two similar standalone bills, H.R. 5491 and H.R. 5413 (the CFPB Data Accountability Act).

The CFPB’s public complaint database is a stellar example of a system that holds institutions accountable and should be replicated throughout the federal government. We strongly support public access to the CFPB complaint database, including the anonymized details of individual complaints, which are essential to public understanding of consumers’ experiences and ensuring that the CFPB continues to shape its agenda in response to those experiences.

September 6, 2016 | Filed under: Other Areas of Interest | Tagged with: Regulatory Enforcement

NACA joins other organizations in voicing  strong opposition to H.R. 5063, a bill that would prohibit settlement agreements where the United States is a party from including certain payment terms to non-federal actors, also known as third-party payments. Settlement terms that result from a federal enforcement action can sometimes include payments to third parties to advance programs that assist with recovery, benefits, and relief for communities harmed by lawbreakers, to the extent such payments further the objectives of the enforcement action. H.R. 5063 will handcuff federal enforcement officials’ ability to negotiate appropriate relief for harm caused to the public by parties that are the subject of the federal prosecution by cutting off any kind of payment to third parties, other than individualized restitution and other direct forms of payment for “actual harm.” 

August 29, 2016 | Filed under: Other Areas of Interest | Tagged with: consumer protection

NACA, other organizations wrote to the Uniform Law Commission’s (ULC) Drafting Committee to Revise the Uniform Unclaimed Property Act (UUPA) expressing concerns about some of the model bill’s provisions. The letter highlights the most blatantly anti-consumer provisions in the final UUPA, so that state legislatures can amend the UUPA to make it more consumer friendly before enacting it. State unclaimed property laws are meant to serve one fundamental purpose: ensure that people can recover property that rightfully belongs to them. Unfortunately, several provisions in the final UUPA run counter to this fundamental purpose.

June 21, 2016 | Filed under: Other Areas of Interest | Tagged with: consumer protection, FTC

NACA joined other public interest groups in a letter to the House Energy & Commerce Committee expressing concern over legislation that would harm the Federal Trade Commission's ability to crack down on scam artists and protect consumers from unfair, misleading, or anticompetitive business practices.