Payday/High-cost Loans

CFA and Other Groups Oppose OCC’s Proposed Rule to Pressure Banks to Support Predatory Lending

CFA joined several consumer, faith, community, and civil rights groups in comments to the Office of the Comptroller of the Currency (OCC) opposing it’s proposed rule that could unreasonably limit banks’ ability to decide not to serve particular entities, including payday and other predatory lenders. Our comment focuses on the unmistakable conflict between, on one hand, requiring banks to engage in safe and sound lending practices, adhere to consumer protections, avoid discriminatory practices, and invest in their communities, while, on the other hand, pressuring them to finance lenders whose models are driven by unaffordable lending. The comment further discusses the reality of reputational risk and how banks’ facilitation of payday lending has heightened that risk in the past and promises to continue to do so going forward.