Letter to HUD asking for delay of ANPR until note sale data is released
As part of the Fair Arbitration Now (FAN) coalition, AFR sent a letter in support of Rep. Green’s amendment to the Consumers First Act, which would restore the Consumer Financial Protection Bureau’s arbitration rule that was repeated by a Congressional Review Act resolution in 2017. View or download a pdf copy of the letter here.
Dear Representative or Senator, We are writing on behalf of 30 undersigned organizations to urge you to co-sponsor the Inclusive Prosperity Act of 2019.
The Proposal—a plainly outcome-driven, 47-page exercise in grasping for straws—has offered no reasonable basis to rescind that Rule. Based on a distorted focus on the Rule’s “dramatic impacts” on lenders’ ability to engage in a predatory practice, rather than on the need to protect consumers, the Proposal claims that the evidence must somehow be “more robust.” If the Rule requires significant changes for payday and vehicle title lenders, it is because the harm to consumers is dramatic. The Bureau’s new approach would ignore its consumer protection mandate and require the agency to hesitate when consumer harm is the most severe.