Letters

Letters

Commenting on Developing Reg Issues


On July 21, 2011 IBAT commented on three rules proposed by federal banking agencies.  In separate letters, IBAT:
  • Expressed belief that Credit Risk Retention rules overreach beyond Dodd-Frank requirements with respect to credit history, loan-to-value ratio, down payment and loss mitigation, and asked that these provisions be removed in final rulemaking;
  • Sought to clarify conflict and confusion between EFTA and U.C.C. § 4A. on the Proposed Rule on Remittance Transfers (Regulation E); and

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