On the recordJuly 29, 2014
I submit the following letter of support of H.R. 5062. July 25, 2013. Re Supervisory Privilege for Nondepository Consumer Lenders Hon. Tim Johnson, Chairman, Senate Banking Committee, Washington, DC. Hon. Mike Crapo, Ranking Member, Senate Banking Committee, Washington, DC. Hon. Jeb Hensarling, Chairman, House Financial Services Committee, Washington, DC. Hon. Maxine Waters, Ranking Member, House Financial Services Committee, Washington, DC. Dear Chairmen and Ranking Members: The American Financial Services Association (``AFSA'') and the undersigned automobile finance companies ask for your support to ensure the privilege protection for state licensed and regulated nondepository consumer lenders under the jurisdiction of the Consumer Financial Protection Bureau (``CFPB'' or ``Bureau'') is fully extended to all such companies and their privileged information--regardless of which state agency happens to be their regulator. The Dodd-Frank Act and Privilege While the Dodd-Frank Act (``Act'') granted the CFPB authority to regulate and supervise a wide range of depository institutions and nondepository consumer lenders, the Act neglected to extend the historical protections over privileged information submitted to bank supervisors, during the course of supervision, to either the CFPB or certain state agencies with whom the Bureau is expected to share information and coordinate examinations. A Flawed Solution The enactment of H.R.…





