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This letter is submitted on behalf of ACA International, American Bankers Association, American Financial Services Association, American Transaction Processors Coalition, Bank Policy Institute, Credit Union National Association, Electronic Transactions Association, Independent Community Bankers of America, National Association of Federally-Insured Credit Unions, National Association of Mutual Insurance Companies, Online Lenders Alliance, Real Estate Services Providers Council, Inc. (RESPRO), Small Business & Entrepreneurship Council, and the U.S. Chamber of Commerce.
We write to urge the Bureau to deny the recent Petition for rulemaking seeking promulgation of a regulation banning pre-dispute arbitration provisions in contracts for consumer financial services.