Comment Letters

Reaching out to Congress and Regulators

Letter to members of the Texas House delegation supporting H.J. Res. 111, which would overturn the recently adopted CFPB rule prohibiting the use of voluntary arbitration agreements.

Letter to Jason Furman of the President's Council of Economic Advisors, commenting on the erroneous information contained in the "Issue Brief" that concluded that community banks have remained healthy post Dodd-Frank. Sept. 6, 2016

Letter to Monica Jackson of the CFPB on the proposed rule limiting the use of arbitration agreements, which specify that consumer disputes may not be resolved by means of class action litigation. Aug. 22, 2016

Letter to Shari Shivers of the Credit Union Department opposing proposed amendments to the Texas Administrative Code to enhance the commercial lending powers of Texas-chartered credit unions. Aug. 22, 2016

Letter to Rep. Larry Gonzales, chairman of the Sunset Advisory Commission, requesting that language be struck from the Sunset Report for the State Bar of Texas that would have required banks holding IOLTA funds to notify the State Bar if those accounts are overdrawn. Aug. 16, 2016

Letter To Melvin L. Watt, director of the Federal Housing Finance Agency, urging the FHFA to strike a language preference question being considered by that agency and the CFPB for inclusion in the URLA. July 19, 2016

Letter to regulators urging their support for the legal efforts underway to reserve the appellate decision on Midland Funding LLC et al. v. Saliha Madden rendered on May 22, 2015 by the U.S. Court of Appeals for the Second Circuit. April 18, 2016

Letter to Shari Shivers of the Credit Union Department opposing a proposal that would expand the field of membership requirements for state-chartered credit unions. April 11, 2016

Letter to Gerard S. Poliquin of the NCUA opposing a proposal that would extensively amend the chartering and field of membership requirements governing federal credit unions. Feb. 8, 2016

Letter to Kelly Hancock of the Senate Committee on Business & Commerce sharing TBA's perspective on the issue of elder financial abuse and how it arose to the forefront of TBA's agenda during the 84th Session of the Texas Legislature. Jan. 21, 2016

Letter to Kelly Hancock of the Senate Committee on Business & Commerce relating to the role that tax lien transfers play in forestalling foreclosure. TBA believes tax lien loans forestall foreclosure because it is more profitable for tax lien lenders to drain as much equity from properties as possible before moving them to foreclosure--a practice called equity stripping. Jan. 21, 2016