Ex parte Letter from ABA

Summary: The American Bankers Association (ABA) opposes the majority of the proposed changes to Regulation X, arguing that many provisions—such as fee prohibitions and language access requirements—exceed the Bureau's statutory authority and impose significant operational burdens. While they support removing the anti-evasion provision to allow for sequential review, they argue the rest of the proposal is unnecessary, lacks evidence-based justification, and could create impractical foreclosure pauses.