Category: Letter

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.

CFE Fund Comment Letter to the Federal Reserve on Faster Payments

Posted on by Katie Plat

The CFE Fund submitted a comment letter to the Board of Governors of the Federal Reserve System in response to their request for public comments on the need for new infrastructure that can enable ubiquitous, nationwide access to safe and efficient faster payments. Speaking from the CFE Fund’s programming and research experience working with nearly 70 mayors across the country, particularly in regard to those that are unbanked, this comment letter calls out the lack of real-time payment and settlement systems as one of the top barriers discouraging people from connecting into the stability of the financial mainstream, and urges a real time payment system.

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.