Project Category: CFE Coalition

CFE Coalition Comment Letter to CFPB (2019)

Posted on by Katie Plat

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.

Supervitamin Quarterly, Issue 15

Posted on by Katie Plat

This issue, Issue 15, highlights the findings from the CFE Fund and Federal Reserve Bank of St. Louis’ 2017 Bank On Data Pilot; along with new Bank On resources; updates on the scaling of the Financial Empowerment Center initiative under the FEC Public platform; early successes seen from CFE Fund’s CityStart initiative; updates on Consumer Financial Protection efforts; and highlights from the fifth year of the Summer Jobs Connect initiative. It also includes local updates from the CFE Coalition, and a guest column from Daniel Davis, Assistant Vice President and Community Affairs Officer at the Federal Reserve Bank of St. Louis.

CFE Coalition Comment Letter to the Office of the Comptroller of the Currency

Posted on by Katie Plat

The CFE Coalition submitted a comment letter to the Office of the Comptroller of the Currency (OCC), in response to their request for public comments on amendments to the Community Reinvestment Act of 1977 (CRA). This letter focused on the CFE Coalition’s support for modernizing the CRA to meet the changing needs of member banks, while preserving the original intent of the law. Based on the Coalition’s on-the-ground experience expanding financial access to millions of people, the CFE Coalition offers recommendations regarding the definition of CRA assessment areas, the eligibility of activities that could receive consideration during the examination process, maintaining and strengthening the service test and ensuring that any proposed evaluation methodology does not undermine the value and incentive for banks to work with local communities.

 

CFE Fund Comment Letters to the Consumer Financial Protection Bureau

Posted on by Katie Plat

The CFE Fund submitted Comment Letters to the Consumer Financial Protection Bureau (CFPB) in response to their request for public comment. Topics include: Civil Investigative Demands and Associated Processes, Rules of Practice for Adjudication Proceedings, Enforcement Processes, Supervision Programs, External Engagements, Public Reporting Practices of Consumer Complaint Information, Rulemaking Processes, Adopted Regulations and New Rulemaking Authorities, Inherited Regulations and Inherited Rulemaking Authorities, Guidance and Implementation Support, Financial Education Programs, and Consumer Complaint Handling Processes.

These letters focused 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.

CFE Coalition CFPB Comment Letter on Payday Loans

Posted on by Katie Plat

The 15-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008.

In this 2016 letter, the Coalition highlights how programmatic experience has shown members the devastating impacts that predatory lending can have on residents. The Coalition applauds the Bureau’s efforts to create strong national regulations to safeguard consumers from abusive and costly practices in the short-term lending market that trap them in cycles of debt, and offers a number of recommendations. These include: the proposed full payment test should include standardized, transparent methods for estimating basic living expenses; access to covered short-term loans should be limited to four per 12 month period under the alternative requirements; the CFPB should implement a reasonable maximum payment-to-income ratio as an alternative to the full payment test to enable financial institutions to offer lower-cost, sustainable installment loans; lenders should be required to meet a clearly defined maximum annual portfolio default rate on all covered loan sequences, regardless of whether they use the full payment test or approved alternatives; and lenders should be required to contribute a percentage of revenue from all covered loans to a fund that supports nonprofit financial counseling.

CFE Coalition 2016 Policy Agenda: Policy Priorities and Recommended Agenda Items

Posted on by Soliant Admin

The 15-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008.

In 2016, the CFE Coalition released its 2016 Policy Agenda, outlining the legislative and regulatory reforms it seeks to advance. Key policy areas of interest include expanding access to financial products and services; improving financial capability; promoting asset building opportunities; and strengthening and expanding consumer financial protections. Specifically, the agenda supports newly-released Consumer Financial Protection Bureau proposed payday loan regulations, expanded access to financial counseling and safe banking products, and a reduction in municipal fees and fines.

CFE Coalition Comment Letter on the FDIC National Survey of Unbanked and Underbanked Households

Posted on by Soliant Admin

The 15-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008.

In this 2015 letter, the Coalition affirms that the information collected through the Federal Deposit Insurance Corporation’s (FDIC’s) National Survey of Unbanked and Underbanked Households is useful and necessary, especially to inform Bank On programming and aligned financial products. The Coalition highlights specific questions from the Survey that have proved especially useful for member cities’ work, and urges the FDIC to keep as many questions as possible in the Survey. Finally, the Coalition asks for the ability to create custom tables from the data; encourages the FDIC to offer training for municipalities and others on how to use the tool; and urges caution as the FDIC explores moving towards online survey responses, given some un/underbanked and low-income consumers’ reluctance to submit personal information via online platforms.

CFE Coalition Comment Letter on the Community Reinvestment Act

Posted on by Soliant Admin

The 15-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008.

In this 2014 letter, the Coalition weighs in on proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. The Coalition recommends a number of factors that the Community Reinvestment Act (CRA) examination process should take into account. First, the Coalition encourages the addition of CRA-based incentives for municipal financial empowerment services, such as for financial institutions that partner with municipalities to offer Bank On appropriate accounts, support children’s savings strategies, and invest in or support integrated financial counseling and coaching services. The Coalition urges that any consideration of alternative product delivery system be balanced by the fact that many low and moderate-income customers rely on full service bank branches, and highlights that cost and range of services, information about account availability, public awareness and customer support are all critical factors. The Coalition also recommends that the Q&A provide specific examples of how community development services can be distinguished from retail banking services, with suggested examples ranging from improving account screening to targeted outreach to low and moderate-income communities and training employees on serving these communities. Finally, the Coalition strongly recommends that assessment areas be revised to include all areas where banks do business, instead of being limited to where banks have a physical presence.

CFE Coalition Comment Letter on Limitations on Terms of Consumer Credit Extended to Service Members and Dependents

Posted on by Soliant Admin

The 15-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008.

In this 2013 letter, the CFE Coalition urges the Department of Defense (DoD) to revise its regulations implementing the Military Lending Act (MLA) to ensure that service members and their families are protected from the full range of abusive lending practices that trap them in cycles of debt.

The Coalition urges the DoD to expand MLA regulations beyond the narrowly defined scope of the types of “consumer credit” subject to protections. Specifically, the Coalition recommends amending the limits to MLA applicability based on loan term, maximum loan amount and loan structure for payday lenders and vehicle title lenders; subjecting direct deposit advance loans to full MLA protections; and ensuring that MLA protections are uniformly applied to the full range of deleterious products targeted at members of the military.