Letter
Joint Letter to Consumer Financial Protection Bureau from Faith for Just Lending on Rule Response, February 13, 2019
Joint Letter to Consumer Financial Protection Bureau from Faith for Just Lending on Rule Response, February 13, 2019
USCCB and Catholic Charities USA join other faith-based groups in letter to the Director of the CFPB, Kathleen Kraninger with comments on the proposal.
We are writing as a broad and diverse coalition of Christian churches and organizations to express our concern over the reopening of the small dollar lending rule. The rule, as it was finalized on October 5, 2017, represented a long-awaited step towards protecting borrowers from the predatory and unjust business practices of payday and auto title lenders. It offered some hope for relief from the debt traps that have devastated so many of our members and vulnerable neighbors.
The reopening of the rule presents both a risk and an opportunity. On the one hand, if it results in delaying and weakening the rule, it will leave millions of vulnerable borrowers exposed to the predatory practices of payday and auto-title lenders. On the other hand, if you use the opportunity to close loopholes in the ability to repay standard, you will advance the CFPB’s mission to protect American consumers.
We encourage you to take this opportunity to strengthen, not weaken, the rule. The rule as finalized seeks to protect vulnerable individuals and families in time of financial crisis from debt traps designed around their inability--as opposed to ability--to repay their loan. 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 the rule was a step in the right direction, but more must be done.