On March 18, BPI submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) on its proposal to delay implementation of the mandatory underwriting provisions under the 2017 final rule on payday lending. The letter asks the CFPB to delay the entirety of the rule, arguing that even with the CFPB’s proposed changes, the payment provisions that would remain in the rule potentially cover a broad range of responsible, safe and sound bank loan products for creditworthy consumers, rather than the vulnerable consumers the rule is intended to protect. The letter further stresses the importance of bank-provided small dollar credit products in furthering access to credit, and of the need for sensible regulation of these products that does not impede banks’ ability to offer low-cost credit to consumers.
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