Submit your comments to the CFPB by May 15th

by The CAB Man Texas on May 3, 2019

CFSA has been urging industry stakeholders to submit a comment letter to the CFPB regarding the  “CFPB Rule Proposal to Reconsider the 2017 Payday Lending Rule.”  

Again, right now the CFPB ATR and Payment Provisions are on hold which is referred to as a “stay.” 

See below for what CFSA is saying we need to do, go for it!

Submit Your Comment by May 15


 The CFPB has issued a 
“Payday Reconsideration” Notice of Proposed Rule Marking and “NPRM,” which seeks comment on whether it should rescind the mandatory underwriting provisions of its 2017 Final Rule. The Payday Reconsideration NPRM has a deadline of May 15 to receive public comments.

CFSA appreciates and supports the CFPB’s proposal to revisit and rescind the mandatory underwriting requirements that were finalized in its 2017 Final Rule for small-dollar lending. From our perspective, the 2017 Rule was a needlessly complex and overbroad proposal that would have caused irreparable harm to industry businesses and eliminated an important form of credit to consumers. At the same time, we remain concerned that the payment provisions, which are contained in the same 2017 Rule, are also not being revisited in this current rulemaking proposal.

At this time, we ask CFSA members to submit comment letters during this rulemaking comment period.
 
To assist our members, and to better ensure a consistent message, CFSA offers a detailed outline with sample themes and messaging that can be used to draft a company (or individual) comment letter.  Here is the link:

https://gallery.mailchimp.com/24e3495ba138af4c830a9e396/files/20d6e1e1-ae11-470f-a3d7-9f9b880d351e/20190325_CFPBNPRM2019_NPRMPaydayReconsideration_CompanyComment_ShortOutline.pdf

Once you have a comment prepared, here’s some information on how to submit it to the government:

Your comment must be received by the government on or before Wednesday, May 15, 2019, at 11:59 pm eastern time. 
 

Be sure to identify the Docket No. CFPB–2019–0006 at the beginning of your company’s comment letter. 
 

You can file your comment letter one of three ways:

Electronic Submission via Regulations.gov at:

https://www.regulations.gov/document?D=CFPB-2019-0006-0001

Email to:

2019-NPRM-PaydayReconsideration@cfpb.gov
 

Mail/Hand Delivery/Courier to Address:
Comment Intake
Bureau of Consumer Financial Protection 
1700 G Street, NW 
Washington, DC 20552

This blog post was written by Michael Brown, President of CAB Consulting and the Texas Organization of Financial Service Centers.  He can be reached at 214-293-8676, or Michael@CreditAccessBusiness.com.

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