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ABA: The American Bankers Association

Krista Shonk

SVP & Senior Counsel, Regulatory Compliance & Policy

Krista Shonk
Krista is vice president of regulatory compliance policy for ABA. In this role, she leads ABA’s advocacy on Community Reinvestment Act modernization and third-party risk management. Krista is a recognized expert on financial institution regulatory and policy matters and has in-depth experience on anti-money laundering requirements and the CFPB’s mortgage servicing rules. Prior to joining ABA, Krista served as associate general counsel for Freddie Mac, where she advised on statutory and regulatory requirements for new products and new activities and managed regulatory filings for new business initiatives. Krista earned a B.A. from Bridgewater College and a J.D. from West Virginia University College of Law. She is a member of the Virginia Bar and serves on the president’s advisory council for Bridgewater College.
  • Staff Analysis
    FAQ: Executive Order on Ensuring Accountability for all Agencies

    March 14, 2025

    On February 18, 2025, President Trump issued an executive order titled Ensuring Accountability for All Agencies (Independent Agency EO or EO).

  • Staff Analysis
    FAQ: Executive Order on Implementing DOGE Deregulatory Initiative

    February 28, 2025

    On February 19, 2025, President Trump issued an executive order titled "Ensuring Lawful Governance and Implementing the President's 'Department of Government Efficiency' Deregulatory Initiative" (Deregulation EO). The executive order—one of several issued by the Trump Administration to downsize and curb the power of Federal agencies—aims to focus regulatory agencies on activities that are "squarely authorized" by Federal law.

  • Staff Analysis
    Pause of Agency Grant, Loan, and Other Financial Assistance Programs

    February 05, 2025

    <span style="letter-spacing: 0.15pt; line-height: 107%;">ABA released a summary of the Administration's funding pause directives and the ensuing litigation by state attorneys general and a consortium of non-profit, healthcare, and small business organizations.</span>

  • Staff Analysis
    FAQ on Presidential Regulatory Freeze Memorandum

    January 23, 2025

    On January 20, 2025, President Trump issued 60-day regulatory freeze memorandum pausing new and in-process regulations.

  • Staff Analysis
    Analysis of the Joint Statement and Request for Information on Bank-Fintech Arrangements Involving Banking Products Distributed to Consumers and Businesses

    August 09, 2024

    On July 25, 2024, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued two documents that address "banking as a service" (BaaS), embedded finance and other arrangements through which banks make available deposit, payment, or lending products that fintechs market, distribute, or otherwise provide to consumers or businesses (also known as end users).

  • Staff Analysis
    10 Takeaways on Third-Party Risk Management Guidance

    August 11, 2023

    The new guidance, which became effective when issued, rescinds and replaces each agency's prior individual guidance on this topic.

  • Comment Letter
    ABA Letter to OCC on Proposal to Rescind the 2020 Rule

    October 29, 2021

    The American Bankers Association (ABA) welcomes the opportunity to respond to the Office of the Comptroller of the Currency's (OCC) proposal to rescind the agency's 2020 rule implementing the Community Reinvestment Act (the 2020 Rule) and replace it with a rule that largely tracks the agency's 1995 Rule, as amended (1995 Rule).; Under this approach, all definitions, performance tests and standards, related data collection, recordkeeping, reporting, and other requirements would revert to those that were in place prior to the issuance of the 2020 Rule.

  • Comment Letter
    ABA Letter on the Proposed Interagency Guidance on Third-Party Relationships: Risk Management

    October 18, 2021

    ABA supports this joint effort. This undertaking is especially valuable as a bank's ability to compete in the marketplace depends increasingly on the institution's ability to leverage the expertise of third-party service providers and manage those relationships prudently.

  • Comment Letter
    Letter to FRB on the ANPR re: CRA Modernization

    February 16, 2021

    The American Bankers Association is pleased to comment on the Advance Notice of Proposed Rulemaking (ANPR) issued by the Board of Governors of the Federal Reserve System (Federal Reserve) that would modernize the regulations that implement the Community Reinvestment Act of 1977 (CRA).

  • Comment Letter
    ABA's Letter to OCC Containing a List of Questions re: New CRA Rule

    October 05, 2020

    The questions were identified by bankers on ABA's CRA Working Group. We share this list in the spirit of collaboration and with the goal of helping the OCC to identify common questions and address information gaps.

  • Comment Letter
    ABA Letter to FDIC on Third-Party Providers of Technology

    September 22, 2020

    ABA appreciates the FDIC's willingness to address some of the hurdles, duplication, and costs associated with managing third-party risk. Increasingly, a bank's ability to compete in the marketplace will depend on its ability to leverage the expertise of third-party service providers.

  • Staff Analysis
    RFI on Standard Setting and Voluntary Certification for Models and Third-Party Providers of Technology and Other Services

    July 22, 2020

    On July 20, 2020, the FDIC issued a Request for Information (RFI) seeking input on the pros and cons of creating a public/private standards-setting organization (SSO) that would ease the time and burden associated with banks' third-party due diligence obligations.

  • Staff Analysis
    FDIC/OCC CRA Proposed Rule

    December 19, 2019

    On December 12, 2019, the FDIC and the OCC proposed major revisions to the regulations implementing the Community Reinvestment Act (CRA).

  • Comment Letter
    Reforming the Community Reinvestment Act Regulatory Framework

    November 15, 2018

    Docket ID OCC–2018–0008

  • Comment Letter
    Comments to CFPB on the 2013 RESPA Servicing Rule

    July 10, 2017

    The American Bankers Association ('ABA') appreciates the opportunity to comment on the Bureau of Consumer Financial Protection's ('CFPB') plan to assess the 2013 RESPA Servicing Rule. The CFPB is conducting its assessment of the RESPA Servicing Rule pursuant to Section 1022(d) of the Dodd-Frank Act. Section 1022(d) requires that the CFPB evaluate each significant rule it issues and publish a report of that assessment within five years of the rule's effective date. In the case of the Servicing Rules, the CFPB must issue its report by January 10, 2019.

ABA Speakers Bureau

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