Ms. Monica Jackson
Workplace for the Executive Secretary
Customer Financial Protection Bureau
1700 G Street, NW
Washington, DC 20552
Re: Docket No. CFPB-2016-0025 / RIN3170–AA40 – Payday, car Title, and Certain High-Cost Installment Loans
Dear Ms. Jackson,
The Consumer Bankers Association (“CBA”)1 appreciates the chance to offer our remarks in reaction to your customer Financial Protection Bureau’s (“Bureau” or “CFPB”) notice of proposed rulemaking for payday, automobile name, and specific high-cost installment loans (“Proposal”). CBA highly supports effective customer defenses and, especially, the concepts of preference, transparency and fairness in consumer relationships.
CBA commends the Bureau for examining the small-dollar credit marketplace and exactly how loan providers in the forex market meet consumers’ need for credit. We think its essential that customers get the services and products they desire and require at reasonable rates as well as on clear terms. We believe that it is incredibly important to weed away bad actors that engage in fraudulent deals or violate laws that are federal. Nevertheless, we think the Bureau’s Proposal will discourage depository that is traditional from staying in or going into the market.