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ABA: The American Bankers Association

Kitty Ryan

Senior Vice President, Regulatory Compliance and Policy

Kitty Ryan
Kitty is vice president and senior counsel for ABA’s Fair and Responsible Banking unit. Kitty joined ABA from Morrison & Foerster, where she was counsel in the financial services practice group, working on fair lending and mortgage issues. Kitty is the former Deputy Assistant Director for the Office of Regulations at the Consumer Financial Protection Bureau (CFPB), where she was instrumental in the planning and oversight of mortgage- and fair-lending related rulemakings, including mortgage servicing regulations, Truth in Lending Act-Real Estate Settlement Procedures Act (TILA-RESPA) Integrated Disclosures rules and the Home Mortgage Disclosure Act. Prior to joining the CFPB, Kitty served as senior regulatory counsel at JPMorgan Chase & Co., where she focused on regulatory issues impacting mortgage and fair lending issues. She also developed her extensive mortgage and fair lending related experience while with the Consumer and Community Affairs Division of the Federal Reserve Board (FRB).
  • Letter to Congress & Regulators
    Letter to CFPB on Circular 2023-03 addressing ECOA

    February 12, 2024

    The ABA and its members urge the Bureau to rescind the Circular and to reissue it as proposed guidance, expressly inviting public comment on the issues identified above.

  • Letter to Congress & Regulators
    Letter to CFPB on Immigration Status in Credit Decisions

    February 12, 2024

    Because ABA and its members welcome guidance that complies with legal requirements while providing useful information and advice, we are offering industry feedback on certain recently published guidance documents.

  • Comment Letter
    Letter to the Agencies on Automated Valuation Models

    August 21, 2023

    ABA's paramount concern is that the proposal likely will over-burden – and therefore discourage - AVM use in mortgage origination.

  • Staff Analysis
    CFPB 1071 Final Rule

    August 11, 2023

    On March 30, the Consumer Financial Protection Bureau (CFPB) released its final rule implementing section 1071 of the Dodd Frank Act.

  • Comment Letter
    Letter to CFPB on the Statement of Policy Regarding Abusive Acts and Practices

    June 30, 2023

    ABA believes the policy statement should be substantially revised if it is to provide helpful and lasting guidance to regulators and the industry.

  • Comment Letter
    Letter to the CFPB on Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders

    March 30, 2023

    Although the proposal is aimed at nonbanks, ABA has three concerns with it. First, the Bureau cannot require banks to register, contrary to the press release's statement that the Bureau might consider doing so in the future. Our second concern is that the proposed rule could extend to bank holding companies and other nonbank affiliates of banks. Third, the Bureau must clarify in the final text of the regulation that nonbank affiliates of banks are exempt from the attestation and written statement requirements.

  • Comment Letter
    Letter to CFPB on Automated Valuation Model

    May 13, 2022

    As the Bureau considers adding a quality control factor for fair lending, it should keep in mind that banks fully support fair lending laws and that their use of models to inform decision making is already heavily regulated.

  • Staff Analysis
    CFPB Statement Regarding Limited English Proficiency

    February 01, 2021

    The Bureau's statement is aimed at encouraging financial institutions to serve LEP consumers, to integrate them into the financial marketplace and thereby foster a more inclusive financial system. The Statement does not announce any new policies or guidance, however, it provides a helpful summary of previous Bureau research, policy and enforcement actions related to LEP consumers, organized under compliance principles and guidelines.

  • Staff Analysis
    CFPB Advisory Opinion on Special Purpose Credit Programs under Reg B

    January 04, 2021

    ABA summary of the CFPB's December 21, 2020 Advisory Opinion regarding special purpose credit programs under Regulation B, which implements the Equal Credit Opportunity Act.

  • Comment Letter
    ABA Letter to CFPB on Section 1071 Proposals Under Consideration

    December 14, 2020

    We support the Bureau's consideration of the costs to small entities of compliance with section 1071. In this regard, we appreciate the Bureau's preliminary decision to consider a simple and clear definition of a small business based on gross annual revenues, to cover only lending to small businesses, and to allow financial institutions to rely on information provided by applicants. These aspects of the outline help address our members' concerns about the burden of compliance with a section 1071 rule.

  • Comment Letter
    ABA Letter to CFPB on ECOA

    December 01, 2020

    We fully support the Bureau's goal with the RFI - to identify opportunities to prevent credit discrimination, encourage responsible innovation, promote fair, equitable and nondiscriminatory access to credit, address potential regulatory uncertainty, and develop solutions to regulatory compliance challenges under the ECOA and Regulation B.

  • Staff Analysis
    California Privacy Rights Act

    November 13, 2020

    On November 3, 2020, Californians approved changes to the 2018 California Consumer Privacy Act (CCPA) through a ballot Initiative known as the California Privacy Rights Act (CPRA). The CPRA provides new rights relating to personal information (PI). With the new rights come new disclosure obligations for businesses subject to the CCPA.

  • Staff Analysis
    CFPB's Proposals Under Consideration for Section 1071 Rulemaking

    September 29, 2020

    On September 15, 2020, the CFPB released an outline of its proposal to implement section 1071 of the Dodd Frank Act, which requires financial institutions to collect and report data on lending to small businesses, including minority-owned and women-owned small businesses. The CFPB will use the outline to elicit feedback from "small entity representatives" subject to the 1071 rules on the outline and on the Bureau's estimate of the one-time and ongoing costs of the 1071 data collection.

  • Staff Analysis
    HUD Final Rule on Disparate Impact

    September 15, 2020

    The final rule intends to align HUD's 2013 disparate impact rule to the Supreme Court's 2015 decision in Inclusive Communities. The ABA's comment letter encouraged this alignment. The final rule adopts the five elements of a disparate impact claim that were in HUD's proposal, with some minor modifications, and clarifies the plaintiff's obligations at the pleading stage and at subsequent stages of a case.

  • Staff Analysis
    Summary of California Office of Administrative Law's Issuance of CCPA Rules

    August 18, 2020

  • Comment Letter
    Letter to CFPB on Small Business Lending Survey

    February 18, 2020

    Letter to CFPB on the survey questionnaire intended to gather information on small business lending.

  • Staff Analysis
    California Consumer Privacy Act FAQs

    December 11, 2019

    ABA FAQs on the California Consumer Privacy Act.

  • Comment Letter
    ABA's Letter to California Office of the Attorney General on California Consumer Privacy Act

    December 06, 2019

    The American Bankers Association appreciates the opportunity to comment on the proposed regulations to implement the California Consumer Privacy Act (CCPA).

  • Staff Analysis
    California Consumer Privacy Act (CCPA)

    November 01, 2019

    ABA summary of the California Consumer Privacy Act's major rules.

  • Staff Analysis
    California Consumer Privacy Act, Summary of Proposed Regulations

    November 01, 2019

    ABA summary on the major proposed rules to implement the California Consumer Privacy Act.

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