Comment Letters

September 3, 2020 | Filed under: Small Dollar Loans | Tagged with: OCC, Predatory Lending, Preemption

National consumer advocacy organizations strongly oppose the Office of the Comptroller of the Currency proposal that would preempt the authority of states and courts to look beyond contrivances to the truth to prevent evasions of state usury laws. The proposal would eliminate state interest rate limits for nonbank predatory lenders in every state as long as a bank’s name is in the fine print.

September 3, 2020 | Filed under: Small Dollar Loans | Tagged with: CLASS Network, OCC, Predatory Lending, Preemption

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 nonbank 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. 

May 15, 2019 | Filed under: Small Dollar Loans | Tagged with: CFPB, Payday Lending

NACA urges the Consumer Financial Protection Bureau not to rescind the ability to repay provision from its 2017 rule on payday loans and to implement the rule as written.

September 20, 2017 | Filed under: Small Dollar Loans | Tagged with: Predatory Lending

NACA joins organizations in supporting the Senate and House companion bills, S. 1659/H.R. 3760, the “Protecting Consumers from Unreasonable Credit Rates Act,” sponsored by Senator Richard Durbin, Senator Jeff Merkley, Representative Matt Cartwright, and Representative Steve Cohen. The Senate and House bills would extend to all consumers a 36 percent usury APR cap. A fair rate cap will protect consumers by curbing abuses in the high-cost small dollar loan market, while permitting responsible lending on reasonable terms to continue. A strong rate cap also has strong public support, with a large majority of the public consistently supporting interest rate caps on payday, car title, and other high-cost loans.1

October 19, 2010 | Filed under: Small Dollar Loans

The nation's largest banks charge customers overdraft fees averaging $35 per transaction, often adding up to hundreds of dollars per day. The most common triggers of overdraft fees are small debit card transactions-which cost the consumer nothing when they are simply denied due to lack of funds. Consumer groups call on the Office of Comptroller of the Currency to end abusive overdraft practices.

January 14, 2010 | Filed under: Small Dollar Loans

 The Restoring America's Commitment to Consumer's Act is an important piece of legislation because it stops the credit card industry's practice of imposing abusive interest rates and fees. By capping credit card interest rates at 16% and limiting the amount of fees charged to consumers, HR 4300 helps end the cycle of debt that burden so many American families.
 

October 28, 2009 | Filed under: Small Dollar Loans

Overdraft loans cost consumers nearly $24 billion each year and are typically charged without consumers’ explicit consent. Fee-based overdraft coverage is, by far, the most expensive way to have an overdraft covered. But financial institutions typically automatically enroll their customers into this coverage, rather than encouraging them to choose among lower cost options. Often, these financial institutions then manipulate the order in which they post transactions, which further maximizes fees.
 

March 30, 2009 | Filed under: Small Dollar Loans

The undersigned consumer, civil rights, small business, investor, community and labor organizations representing tens of millions of Americans strongly urge you to vote for H.R. 627, the Credit Cardholders' Bill of Rights Act (Rep. Maloney), when it is brought to a committee vote as early as this Wednesday, 1 April 2009. The bill passed the House on an overwhelming 312-112 vote, as HR 5244, in September 2008. It enjoys broad public support.
 

March 30, 2009 | Filed under: Small Dollar Loans

We, the undersigned civil rights, labor, consumer, housing and community groups, write to thank the Federal Reserve Board for bringing attention to abusive overdraft practices while urging you to choose the far stronger opt-in proposal.1 For a rule addressing fee-based overdraft to adequately protect consumers, it must at a minimum require institutions to obtain consumers’ affirmative consent. An opt-out arrangement will do little to alter the status quo.
 

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