American Bankers Association, America’s Credit Unions, and Independent Community Bankers of America wrote a letter to CFPB Director Rohit Chopra to address their concerns that the CFPB’s proposal for rulemaking on non-sufficient funds (NSF) and overdraft fees triggers the statutorily required Small Business Regulatory Enforcement Fairness Act (SBREFA) review as the rulemaking will have a significant economic impact on banks and credits unions with assets of $850 million or less. The trade groups commented: