CFE Coalition Comment Letter to CFPB (2019)

The 16-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008. In this 2019 letter, the Coalition responds in opposition to the Consumer Financial Protection Bureau’s (CFPB) Notice of Proposed Rulemaking (NPRM) rescinding ability-to-repay requirements governing payday, vehicle title, and certain high-cost installment loans. The Coalition believes these underwriting provisions are crucial, and rescinding them would weaken a much needed rule intended to protect individuals and families from the harmful effects of high-cost and often predatory payday and car-title loans.

This letter focuses on local governments’ experiences with consumer financial instability, and both individual’s and businesses’ need for a fair and dependable consumer financial marketplace. The CFE Fund’s letters also emphasized governments’ interest in preserving and protecting social service gains from predatory business practices that would strip them away, and offered to assist current leadership to help achieve these critical priorities.