Testimony & Public Comments

As the trade association representing financial service centers nationwide, FiSCA testifies before Congressional committees and governmental agencies on a variety of industry related subjects.  In addition, FiSCA serves as the leading voice for financial service centers in responding to regulations which pertain to the industry. 

Copies of recent testimony and FiSCA comments can be found below:

FiSCA Testimony

• Statement of Financial Service Centers of America Before the U. S. House of Representatives Committee on Ways and Means Subcommittee on Social Security Regarding Direct Deposit of Social Security Benefits

Sept. 12, 2012

• Statement of Financial Service Centers of America Before the U. S. House of Representatives Committee on Ways and Means Subcommittee on Social Security Regarding Protecting Social Security Beneficiaries from Predatory Lending and Other Harmful Financial Institution Practice

June 24, 2008

• Oral Statement of Scott K. McClain, Deputy General Counsel of Financial Service Centers of America, Before the US House Committee on Financial Services Subcommittee on Oversight and Investigations, Regarding Suspicious Activity and Currency Transaction Reports: Balancing Law Enforcement Utility and Regulatory Requirements

May 10, 2007

• Written Testimony of Scott K. McClain, Deputy General Counsel of Financial Service Centers of America, Before the US House Committee on Financial Services Subcommittee on Oversight and Investigations, Regarding Suspicious Activity and Currency Transaction Reports: Balancing Law Enforcement Utility and Regulatory Requirements

May 10, 2007

• Oral Statement of Gerald Goldman, General Counsel of Financial Service Centers of America, presented at the Subcommittee on Financial Institutions and Consumer Credit

June 21, 2006

• Written Testimony of Gerald Goldman, General Counsel of Financial Service Centers of America, presented at the Subcommittee on Financial Institutions and Consumer Credit

June 21, 2006

FiSCA Presentations/Speeches

• Presentation of Joseph Coleman, FiSCA Chairman, to the FDIC’s Committee on Economic Inclusion

October 24, 2007

• Presentation of Dr. Patricia Cirillo to the FDIC’s Committee on Economic Inclusion

October 24, 2007

FiSCA Written Comments

• FiSCA's Comments to FinCEN re:  BSA Required Electronic Filing

• FiSCA's Formal Comments to the Consumer Financial Protection Bureau re:  Defining Larger Participants in Certain Consumer Financial Products and Services Markets

• FiSCA's comments to the Board of Governors of the Federal Reserve System on the proposed rule on debit interchange.  Docket No. R-1404, RIN No. 7100 AD63

• Position Statement of Financial Service Centers of America Regarding the Proposed Consumer Financial Protection Agency Act of 2009
  

October 2009

• FiSCA Comment to Social Security Administration re: Use of Master and Sub Accounts and Other Payment Arrangements for the Payment of Benefits Docket No. SSA-2008-0023

June 20, 2008

• FiSCA's comments to the Department of Defense (DOD) on Proposed Regulations on Limitations on Terms of Consumer Credit Extended to Military Service Members and Dependents 

June 11, 2007

• FiSCA's Response to FinCEN Advanced Notice of Proposed Rulemaking (RIN 1506-AA85) relating to banking services to money services businesses (MSBs)
  

July 10, 2006