Even within our broad coalition, it is exceedingly rare for so many organizations to come together and to speak with one voice. The tremendous outpouring of opposition to high-cost, short-term loans that put people in a cycle of debt, whether issued by banks or nonbanks, illustrates the importance of this issue to people across the country.
Letter to HUD asking for delay of ANPR until note sale data is released
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.
We, the undersigned 429 civil rights, consumer, labor, faith, veterans, senior, business, and community organizations from 46 states plus the District of Columbia write to vehemently oppose the proposed rescission of the common sense ability-to-repay requirements of the Consumer Financial Protection Bureau (the Bureau)’s 2017 payday and vehicle title loan rule (“Ability-to-Repay Rule” or “Rule”).