Americans for Financial Reform

Government Category: Comments & Letters to Regulators

LETTER TO REGULATORS: Broad Opposition to the CFPB’s Plan to Engage in Payday Loan Disclosure Testing

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 We do so in the broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from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.

Letters to Regulators: Comment Letter to the CFPB on the Equal Credit Opportunity Act

AFREF and 47 organizations submitted comments on the CFPB’s RFI on the Equal Credit Opportunity Act (ECOA) and Regulation B. Our comments urged the Bureau to take no action that would weaken the ECOA in any way and consider certain steps to improve and strengthen fair lending protections under ECOA to make it stronger and more effective tool for fighting credit discrimination.

Letter to Regulators: Letter to the Small Business Administration urging them to maintain strong information collection requirements under the Paycheck Protection Program

Americans for Financial Reform Education Fund (AFREF) and Main Street Alliance (MSA) respectfully urge the Small Business Administration (SBA) to maintain the information collection under the Paycheck Protection Program (PPP) new Loan Necessity Questionnaire for recipients and encourage the SBA to support robust supplemental disclosure requirements for PPP recipients.