Letter to Regulators: Comprehensive Comment On CFPB’s Proposal To Repeal Payday Rule
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.