Public Comments

We urge the CFPB to issue a strong final rule that, once and for all, stops payday and other high­ cost lenders from ensnaring people and their families in a debt trap. With its ever-growing wealth and income gaps, our country cannot afford to suffer the disastrous effects of a too­-moderate rule that would allow payday lenders continued latitude to make predatory, unaffordable loans.

We, the 131 signatories to this letter, represent a diverse cross-section of elected officials, government, labor, grassroots organizing, civil rights, legal services, faith-based and other community organizations, as well as community development financial institutions. We respectfully request that the CFPB count this letter as 131 comments.

Organizations based in the 14 states, plus the District of Columbia, where payday lending is prohibited by state law, urge the CFPB to issue a final rule that will bolster states’ efforts to enforce their usury and other consumer protection laws against payday lenders, debt collectors, and other actors that seek to make, collect, or facilitate illegal loans in our states.

New Economy Project opposes A.9634/S.6985, which would permit New York check cashers to make loans. The bill would allow check cashers, which have no experience as lenders, to make loans to New Yorkers and small businesses in New York, without ensuring the safety and soundness of those loans. By allowing an unprecedented and unwarranted expansion of check cashers’ authority, the bill would pave the way for high-cost, predatory loans that New York has long successfully fought to keep out of our state. New Economy Project opposes allowing New York check cashers to make loans, whether to small businesses or to individual borrowers.

Chase has consistently failed to meet community credit needs in low- and moderate-income neighborhoods – and is in fact harming many lower-income people and communities – in New York City. Giving Chase a Satisfactory or better CRA rating would effectively reward the bank for its illegal, discriminatory, and abusive actions and practices. We call on the OCC to assign a less-than-Satisfactory rating that holds Chase accountable.