Letter
Joint Letter to Consumer Financial Protection Bureau from Faith for Just Lending Coalition, May 13, 2019
Faith for Just Lending Comments in Letter to Consumer Financial Protection Bureau regarding the Proposal to Rescind Ability-to-Repay Requirements Governing Payday, Vehicle Title, and Certain High-Cost Installment Loans, May 13, 2019
Joint Letter to Consumer Financial Protection Bureau on Proposal to Rescind Ability-to-Pay Requirements
USCCB and Catholic Charities USA join 9 other faith-based groups in letter to the Director of the CFPB, Kathleen Kraninger with comments on the proposal.
The Faith for Just Lending coalition respectfully submits the following comment in response to the above-referenced Notice of Proposed Rulemaking. In 2017, the Consumer Financial Protection Bureau finalized new rules to curb predatory payday and car title lending practices and we supported the finalized rule. Faith for Just Lending represents millions of Christians in the United States, from a wide range of denominations and traditions, and we are united in our desire to see predatory lending practices ended. Scripture teaches us to respect the God-given dignity of every person. Exploiting the economic hardship of our neighbors is sinful.
We support the finalized Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans which sought to protect vulnerable individuals and families in times of financial crisis from debt traps designed around their inability--as opposed to ability--to repay their loan. Requiring a lender to make a determination of a borrower’s ability to repay is a longstanding principle of the U.S. banking system. A strong rule must not only have strong upfront underwriting requirements, but effective back-end protections against repeated flipping of the loans as well. We believe that these efforts are a step in the right direction. We therefore ask that the ability to repay standard be upheld and not eliminated from the payday rule.
We do not support any exemption from the borrower's ability to repay standard. The sanctioning of usurious loans contradicts our faith traditions. The CFPB must strengthen its proposal to not allow this exception from its ability to repay test.