Letter from 80 groups opposing the CFPB’s changes to its no-action letter policy and new sandbox proposal
Letter from 80 groups opposing the CFPB’s changes to its no-action letter policy and new sandbox proposal
Letter urging the CFPB to oppose the banking agencies’ proposal to raise the appraisal exemption threshold
AFR Education Fund was among the 18 organizations that submitted these comments responding to the CFPB’s RFI on data collection on December 27, 2018. You can view or download pdf of the letter here.
The rule, which was years in the making, created vital protections for consumers of payday, car title, and some longer-term loans to ensure that predatory lenders don’t trap customers in unaffordable loans. Underlying the rule is the common-sense principle that lenders should consider whether borrowers have the ability to repay a loan before they risk their financial well-being.
Today, Senator Reed (D-RI), Senator Brown (D-OH), and forty-seven other senators sent a letter to acting Consumer Financial Protection Bureau Director Mick Mulvaney, calling on the bureau to continue supervision of lending made to active duty service members and their families to ensure that lenders are complying with the Military Lending Act.
“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”
“What Mulvaney is really interested in is not serious research, but information that advances the interests of the Wall Street banks and predatory lenders he serves.”
“America is facing an ongoing student debt crisis, with outstanding student debt surpassing $1.5 trillion and over 8 million borrowers in default on their student loans. Closing the Office for Students is like shuttering the fire department in the middle of a three-alarm fire,” said Alexis Goldstein, senior policy analyst at Americans for Financial Reform.
“The RFIs pose questions that are almost entirely from an industry perspective and are insufficiently specific to elicit meaningful comment. The RFIs hint at changes desired by industry without providing enough detail to inform members of the public who do not have experience with the internal workings of the Bureau or the implications of the questions. This process weighted in industry’s favor is not consistent with the CFPB mandate to focus on consumer protection.”
“In 2013, the FDIC and OCC issued guidance aimed at curbing the harms of these debt trap loans. At the same time, the Federal Reserve issued a supervisory statement to the same end… But today, banks are attacking the FDIC and OCC protections that have prevented banks from trapping people in unaffordable payday loans.”
We write to ask for the bank’s pledge that it will not begin making payday loans, and that it will oppose the
rollback of the regulatory guidance, which would make it easier for other banks to do so.