December 14, 2020

Comment Intake
Consumer Financial Protection Bureau Attention: PRA Office
1700 G. Street NW
Washington, DC 20552

Submitted electronically via regulations.gov

The Americans for Financial Reform and the undersigned consumer, civil rights, community and faith- based organizations oppose the Bureau’s plans to engage in payday loan disclosure testing. We do so in the broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from the harms associated with payday lenders’ practice of making payday loans without reasonable ability-to-repay determinations. New disclosures would only provide a false veneer of protections that payday lenders would use to bolster their opposition to meaningful consumer protections against unaffordable loans.