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.
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.
NACA joins other consumer, civil rights, small business, and other community organizations to express strong opposition to new federal nonbank lending charters that would enable chartered entities to avoid state interest rate caps, other state consumer protection laws, and state oversight, that put consumers and small businesses at risk.