In this week’s Washington Wire, Congress has left D.C. in the lead up to the election, and the update this week focuses on the importance of the deadline Friday for comments on the CFPB Small Dollar Loan Proposal.
CUNA’s comment letter, which will be filed this week, will emphasize that rulemaking intended to address abuses in the small dollar market should not cover credit unions, reiterating CUNA’s call for the CFPB to exempt credit unions from the proposal. CUNA will address the provisions of the proposal that will make it more difficult for consumers to access credit from credit unions. It also will make a legal argument that the CFPB has exceeded its statutory authority by applying this proposal to credit unions using its Unfair, Deceptive, and Abusive Actions and Practices authority, despite insufficient evidence to show credit unions engaged in the harm perpetrated by other actors that the rule intends to address.
CUNA’s grassroots push is for credit union employees to send the CFPB emails describing how they have helped members with short-term, small dollar loans. Many credit unions will want to send a more substantive comment letter describing concerns regarding the impact the proposal will have on members’ ability to access credit. As you prepare your letter, refer to a summary of the proposal. When discussing the proposal, describe the impact it will have on your members.
Comment letters can be sent through PowerComment or emailed directly to the CFPB here. Be sure to reference the following in the subject line: CFPB Proposed Rule Payday, Vehicle Title, and other Covered Loans; Docket No. CFPB-2016-0025.
For a list of suggested questions to ask, read Washington Wire.