Banking

Policy Analysis

Comments to the Social Security Administration Regarding the Use of Master and Sub Accounts and Other Account Arrangements for the Payment of Benefits Docket No. SSA 2008-0023, June 20, 2008 PDF (200KB)

Comments to the Federal Regulators on the InterAgency Guidance on Exempt Benefits, November 27, 2007 PDF (154KB)

Comments of the NCLC and NACA Regarding Advance Notice of Proposed Rulemaking Relating to Unfair or Deceptive Acts or Practices, November 6, 2007 (PDF 528KB)

Frozen Out: A Review of Bank Treatment of Social Security Benefits, Testimony before the Committee on Finance and Appendices to Testimony, September 20, 2007 PDF

Response to MBA Policy Paper on Suitability, February 1, 2007 PDF 14KB

Comments: regarding the proposed amendments to Reg E on electronic debiting of NSF fees, September 28, 2006 PDF (408KB)

Comments: Request for Information on Electronic Benefits Transfer System for Victims of Disaster, April 14, 2006 PDF (619KB)

Letter: to Senate Banking Committee Regarding Bernanke Nomination, October 24, 2005 PDF (51KB)

Comments: regarding the proposed amendments to Reg E on ATM disclosures, October 5, 2005 PDF (52KB)

Testimony: before the Senate Committee on Banking, Housing and Urban Affairs regarding Current Proposals Considered for Regulatory Relief Legislation, June 21, 2005 PDF (179KB)

Comments: regarding Petition for Rulemaking to Preempt Certain State Laws Federal Deposit Insurance Corporation, May 16, 2005 PDF (353KB)

Testimony: to the Subcommittee on Financial Institutions and Consumer Credit regarding “Helping Consumers Obtain the Credit They Deserve”, May 12, 2005 PDF (105KB)

Comments: regarding Proposed Amendment to Regulation J and Regulation CC Regarding Remotely Created Checks, May 2005 PDF (67KB)

Comments: on Federal Check 21 Act: Banks No Longer Will Return Original Cancelled Checks, October 2004

Testimony: to the Senate Committee on Banking, Housing and Urban Affairs regarding All Current Proposals for Legislation on Financial Services Reform, June 22, 2004 PDF (146KB)

Comments: regarding Economic Growth and Paperwork Reduction Act “EGRPRA”, April 2004 PDF (144KB)

Comments:regarding the Proposed Revisions to Regulations B, E, M, Z, DD and the Official Staff Commentaries, January 2004

Comments: regarding the proposed rules on Customer Identification Programs for Banks, Savings Associations and Credit Union, January 2004

Comments: to the FRB on Bounce Protection Products, April 2003 PDF (203KB)