CR Letter Urging CFPB to Preserve Underwriting Protections for Payday and Auto-Title Loan Borrowers

SUMMARY: Consumer Reports comments on the Consumer Financial Protection Bureau’s proposal to rescind the 2017 Final Rule’s underwriting provisions for payday, auto-title and short-term installment loans. The letter urges CFPB director Kraninger to preserve the 2017 Final Rule, noting that the Bureau has not demonstrated a reasonable basis for this drastic reversal of policy; and that if the proposal is implemented, it will gravely harm consumers.