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ABA: The American Bankers Association

Kitty Ryan

Senior Vice President, Fair and Responsible Banking

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).
  • 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, Summary of Proposed Regulations

    November 01, 2019

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

  • Staff Analysis
    California Consumer Privacy Act (CCPA)

    November 01, 2019

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

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