“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.”
AFR released the policy brief linked below concerning the role of private equity in the Toys R’ Us bankruptcy and the importance of taking action to limit private equity predation on the businesses they own. The Toys R’ Us Bankruptcy And Private Equity Predation.
“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.”