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Via Electronic Submission
The Honorable Richard CordrayConsumer Financial Protection Bureau1700 G Street NWWashington
Re: Proposed rulemaking on payday, automobile name, and specific high-cost installment loans, Docket No.
Dear Director Cordray:
We, the 131 signatories to the page, represent a cross-section that is diverse of officials, federal federal government, work, grassroots arranging, civil legal rights, legal solutions, faith-based as well as other community companies, along with community development banking institutions. We respectfully request that the CFPB count this page as 131 commentary.
Together, we urge you to definitely issue a stronger payday lending rule that ends the cash advance financial obligation trap. While the CFPB makes to issue a last guideline to deal with payday financing nationwide, we urge you not to ever undermine our stateвЂ™s longstanding civil and criminal usury laws and regulations. Certainly, we urge one to issue a guideline that improves our current defenses.
Whilst the CFPB certainly acknowledges, a summary of signatories for this breadth and magnitude is certainly not you need to take gently. This page reflects the positioning of greater than 38 state and neighborhood elected officials, the NYC Department of customer Affairs, the Progressive Caucus of this NYC Council вЂ“ also as 92 businesses that represent a diverse spectral range of communities, views, and constituents. Our company is worried that the CFPB is poised to issue a rule that is weak wouldn’t normally only set a reduced bar for the whole nation, but that will additionally straight undermine our stateвЂ™s longstanding ban on payday financing.
As New Yorkers, we think we’ve a specially appropriate viewpoint to share. Significantly more than 90 million Americans вЂ“ nearly a 3rd regarding the country вЂ“ real time in states like ny where lending that is payday unlawful.