AFSA Submits Three Comments on Critical Rulemakings February 11, 2019 AFSA this week submitted three comment letters to federal agencies.The first letter is in response to the Federal Deposit Insurance Corp.’s (FDIC) request for comment on the agency’s process for approving new state chartered banks. The letter spelled out the importance that the creation of new industrial banks has and pushed the FDIC to make the process easier. FDIC Chair Jelena McWilliams noted in recent comments that, “Over the past decade, de novo activity has screeched to a historic halt. As FDIC chair, one of my key priorities is to encourage new bank formation. The FDIC needs to do its part to make that happen.” The second letter addressed the Federal Trade Commission’s (FTC) proposed revision of the Red Flags Rule and Card Issuers Rule, collectively referred to as the Identity Theft Rules. The letter notes that AFSA and its members overwhelmingly support the FTC’s goal of protecting consumers from identity theft and that the rules do not warrant modification or rescission. It also highlighted that compliance costs incurred by financial institutions at the rules inception were significant and any revision would drive up those costs unnecessarily. The third letter addressed the Consumer Financial Protection Bureau’s (CFPB) proposed no-action letter policy and Product Sandbox. AFSA supports both the policy and the creation of the sandbox as an important tool in financial services innovation. All three letters can be found in the Legal & Regulatory area of the AFSA website.