Lending and Leasing

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FSR advocates on behalf of members that provide loans and leases to customers, including mortgage lending and servicing, credit card lending, auto and commercial equipment leasing, and lending to students and military service members.

Current Lending & Leasing:

  • GSE Reform
  • FHA Reform
  • Mortgage lending and servicing compliance requirements
  • Military service member and small business lending and serving requirements
  • Fair lending and disparate impact
  • Credit card compliance requirements
  • Secured finance, including indirect auto lending, privacy notices, CFPB privilege, and international harmonization of regulations

 

Comment Letter re: Physical Commodities Activities of Financial Holding Companies ANPR, 4-16-14

The Financial Services Roundtable welcomes the opportunity to provide comments on the above-cited advanced notice of proposed rulemaking (“ANPR”) issued by the Board of Governors of the Federal Reserve System on January 21, 2014. The ANPR requests public comment on various issues related to physical commodities activities conducted by...

Joint Trade Letter re: Physical Commodities Activities of FHCs Federal Reserve ANPR, 4-16-14

The Associations strongly believe that the public benefits of continuing to permit FHCs and their non-bank affiliates to engage in physical commodities activities greatly outweigh the potential risks of those activities, whether conducted under the complementary, grandfathering or merchant banking authorities.

Joint Trade Letter re: Physical Commodities Activities of Financial Holding Companies ANPR, 4-16-14

Because of the importance of merchant banking activities to our members, small- and medium-sized businesses throughout the country and the broader economy, we believe it is critical to address specifically the Federal Reserve's physical commodities ANPR’s discussion of, and questions regarding, the general risks associated with merchant banking...

Letter re: OCC Guidelines on Heightened Standards for Large Insured National Banks & Insured Federal Savings Associations

The purpose of the Proposed Guidelines is to establish minimum standards for the design and implementation of risk governance frameworks of insured national banks, Federal savings associations, and insured Federal branches of foreign banks, with average total consolidated assets of $50 billion or more (together, Bank) and minimum standards for...

FSR: Action on Housing Finance Reform Encouraging

“This is another demonstration that Congress is serious about the need to reform the housing finance system by winding down Fannie Mae and Freddie Mac and replacing them with a new structure that provides more private capital and maintains liquidity,” said FSR’s Housing Policy Council President John Dalton.