At a CFPB hearing in Richmond, Va., AFR delivered a letter in which a remarkable array of civil rights, faith, economic justice, elder, community and civic organizations – 500 altogether, including groups from all 50 states – applaud the CFPB for its commitment to this issue and urge it to develop and implement regulations that finally put payday, car-title and other small-dollar lenders “on the same footing as other lenders, requiring them to play by the rules and make fair loans.”
“Few practices are as abusive, unfair, and deceptive as the widespread use of forced arbitration clauses in most consumer contracts, including credit cards, student loans, debt settlement, credit repair, auto financing, and payday loans. Forced arbitration funnels consumers into a private system set up by corporations to protect and hide harmful and unlawful corporate behavior.”
“While the [proposed] rules are generally strong, we offer several suggestions below for strengthening the rules and closing loopholes. In particular, the CFPB should ban all overdraft fees; apply credit card protections to all credit transferred to a linked prepaid card; and limit fees before account opening and beyond the first year. We also urge the CFPB to require prepaid card funds to be held in accounts protected by deposit insurance and to adopt stronger rules to prevent coercive use of payroll, public benefit, student, released prisoner and other prepaid cards.”
AFR submitted comments to the CFPB on the agency’s proposed amendments to its mortgage servicing regulations. AFR appreciates the CFPB’s attention to dealing with continuing problems facing borrowers seeking loan modifications, supports proposed steps to address them, and urges further changes to do so more effectively.
“Supervision of nonbank auto financial institutions will bring much-needed attention to otherwise
lightly-regulated companies, will ensure compliance with consumer financial laws, and will
ensure that auto financing by banks, already subject to CFPB supervision, is not at a competitive
disadvantage.”
AFR was joined by 546 civil rights, consumer, labor, faith and community organizations from all 50 states in a letter urging the CFPB to put in place strong rules that will end abusive practices in ‘quick fix’ consumer lending such as payday, auto-title and installment loans.
AFR joined 47 organizations in supporting the CFPB’s work to make its complaint database public and accessible by consumers. This will help consumers make more informed decisions about how to choose the best products and services for their needs, and how to protect themselves from problems.
AFR submitted a comment to the Consumer Financial Protection Bureau offering some suggestions on how to strengthen their proposed rule on defining “larger participants” in the international money transfer market. This proposed rule, if adopted, would be the fourth in a series of rulemakings to define ‘larger participants’ in various consumer financial product markets. AFR’s recommendations include expanding the criteria CFPB uses to define larger participants, and covering domestic as well as international money transfers under their supervisory purview.
AFR and more than 100 consumer, civil rights, labor and community organizations submitted a letter to the CFPB urging the Bureau to issue a strong rule to address unfair, deceptive or abusive practices in the payday and small dollar loan market.
AFR submitted a comment letter to the CFPB supporting their proposed guidance clarifying the relationship of their servicing rules to stronger state laws. The letter also makes suggestions for improvement.