This letter is submitted on behalf of the U.S. Chamber of Commerce by the Center for Capital Markets Competitiveness (“CCMC”) and the U.S. Chamber Institute for Legal Reform (“ILR”). The Chamber created CCMC to promote a modern and effective regulatory structure for capital markets to function well in a 21st-century economy. ILR champions a fair legal system that promotes economic growth and

We write regarding the recent Petition for rulemaking submitted by the National Association of Consumer Advocates, Public Citizen, the American Association for Justice, Public Justice, the National Consumer Law Center, Consumer Federation of America, the UC Berkeley Center for Consumer Law & Economic Justice, Americans for Financial Reform and Better Markets, Inc. (“Petitioners”) to ban pre-dispute arbitration provisions in contracts for consumer financial services.