We, the undersigned consumer, labor, business, senior, economic justice, and community organizations from Maine, urge you to protect Maine’s low-income families, especially women, senior citizens, minority families, and veterans and members of our armed forces who are the target of payday lenders.
October 6, 2016
The Honorable Richard Cordray
Director, Consumer Financial Protection Bureau
1700 G Street, NW
Washington, DC 20552
Docket No: CFPB-2016-0025 or RIN 3170-AA40
Dear Director Cordray:
We thank you for the opportunity to comment on CFPB’s proposed rule creating consumer protections for payday, vehicle title, and certain high-cost installment loans.
We, the undersigned consumer, labor, business, senior, economic justice, and community organizations from Maine, urge you to protect Maine’s low-income families, especially women[1], senior citizens[2], minority families[3], and veterans and members of our armed forces[4] who are the target of payday lenders.
Maine is a leader in consumer finance protection—capping interest rates and finance charges, requiring licensing and surety bonds, and mandating truth-in-lending. Yet, we still have too many illegal loans being issued in Maine by on-line and out-of-state companies who ignore our laws. We need to have a CFPB rule that strengthens and supports Maine’s strong consumer protections.
We urge you to adopt a rule that:
- Applies the ability to repay standards to all covered loans with no exceptions.
- Imposes a 60-day waiting period between loans, rather than the proposed 30 days.
- Includes a presumption of unaffordability if the borrower is delinquent by even one day or has not repaid 75% of the loan principle.
- Requires lenders to assess a borrower’s basic living expenses as part of the ability to repay standard rather than to rely on default rates.
- Deems the making or offering loans in violation of our state laws an abusive practice.
Only a comprehensive federal framework, free of these loopholes, can supplement Maine’s existing state protections and help stop our most vulnerable consumers from becoming trapped in debt they cannot repay.
Thank you for your consideration.
Sincerely,
Matt Schlobohm
Executive Director
Maine AFL-CIO
Laura Buxbaum
Senior Vice President, Public Policy and Resource Development
Coastal Enterprises, Inc.
Leo J. Delicata, Esq.
Public Policy Advocate
Legal Services for the Elderly
Garrett Martin
Executive Director
Maine Center for Economic Policy
Jessica Maurer
Co-chair
Maine Council on Aging
Robyn Merrill
Executive Director
Maine Equal Justice Partners
Jesse Graham
Executive Director
Maine People’s Alliance
Will Ikard
Director
Maine Small Business Coalition
Ramona C. Welton
President
Maine State Employees Association – SEIU Local 1989
Betsy Sawyer-Manter
Executive Director
Seniors Plus
Danna Hayes
Director of Public Policy
Maine Women’s Policy Center
Eloise Vitelli
Director of Program and Policy Development
New Ventures Maine
cc: Hon. Senator Susan Collins
Hon. Senator Angus King
Hon. Representative Chellie Pingree
Hon. Representative Bruce Poliquin
[1] Bhaskaran, Suparna, “Pinklining: How Wall Street’s Predatory Products Pillage Women’s Wealth, Opportunities, & Futures”, June 2016, Available at: https://d3n8a8pro7vhmx.cloudfront.net/acceinstitute/pages/100/attachments/original/1466121052/acce_pinklining_VIEW.pdf?1466121052&utm_source=MECEP+Matters+July+2016&utm_campaign=July+2016+MECEP+Matters&utm_medium=email
[2] Center for Responsible Lending. “Bank Payday Loans Continue; Seniors Face Particular Risks,” 2013. Available at: http://www.responsiblelending.org/media/new-research-bank-payday-loans-continue?utm_source=MECEP+Matters+July+2016&utm_campaign=July+2016+MECEP+Matters&utm_medium=email
[3] Pew Charitable Trust. “Who Borrows, Where They Borrow, and Why,” 2012. Available at: http://www.pewtrusts.org/~/media/legacy/uploadedfiles/pcs_assets/2012/pewpaydaylendingreportpdf.pdf
[4] Center for Responsible Lending. “CRL, CRC Leaders: Honor Vets by Protecting Them from Payday Lending Scams,” November 10, 2014. Available at: http://www.responsiblelending.org/media/crl-crc-leaders-honor-vets-protecting-them-payday-lending-scams
