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Members of the Consumer Law Advocates, Students, and Scholars (CLASS) network submitted comments to the Office of the Comptroller of the Currency in response to its proposed rule that would allow non-bank lenders to avoid state law that currently protects many of these consumers. The rule will give new life to the “rent-a-charter” schemes that preyed on consumers in the early 2000s – schemes the OCC itself acted to eliminate.

**The C.L.A.S.S. Network is a joint project of the National Association of Consumer Advocates, the UC Berkeley Center for Consumer Law & Economic Justice and Berkeley Law’s student-run Consumer Advocacy & Protection Society (CAPS) to establish and expand a nationwide network of law school student organizations dedicated to the promotion of consumer law.