“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.”
“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.”
View or download a PDF version of the letter here. April 12, 2018 Dear Representative: On behalf of Americans for Financial Reform, we are writing to urge you to vote against HR 4790, which is being considered on the House floor this week.[1] This bill would undermine the implementation of the Volcker Rule (Section 619
AFR sent a letter to Congress opposing a bill that would massively undermine the oversight of non-bank financial companies that are crucial to financial stability.
AFR sent a letter to Congress opposing a bill that would severely weaken stress testing–a key element of bank supervision and oversight.
Americans for Financial Reform wrote to the Department of Education to voice concerns with two applications they have proposed for higher education institutions seeking access to emergency relief funds. In addition to creating barriers to accessing the funds, the forms are not available in Spanish, which will preclude potential applicants in Puerto Rico from accessing needed funds.
