Consumer Federation of America submitted comments to the Massachusetts Premium Finance Board in support of a lower maximum interest rate cap to protect consumers and ensure they are not overcharged. Premium financing consists of borrowing funds from a third party to cover the cost of an insurance policy and paying it back in installments. The Board has the power to regulate interest rates in this area, and CFA urges that the maximum interest rate cap be reduced from 18% to 6%, which is more in line with current circumstances.