National letter to CFPB re: Supervision and enforcement of fintech products and fee models that threaten to evade credit, consumer protection, and fair lending laws
National letter to CFPB re: Rescind earned wage access advisory opinion and sandbox approval and treat fee- based earned wage access products as credit
Letter of complaint to the FDIC from CEI re: high cost loan products facilitated by Capital Community Bank
CEI Letter to the FDIC re: CC Connect loans | June 09, 2021
"The Center for Economic Integrity respectfully urges the FDIC to conduct an investigation of FDIC-supervised Capital Community Bank (CCBank), a Utah bank. The FDIC should invoke its still-in-effect Supervisory Policy on Predatory Lending to prohibit CCBank from participating in a scheme enabling payday and car title lenders to evade state usury laws passed specifically to protect consumers."
Attachment: Roster of CCBank loan products | Updated July, 2021
Letter of acknowledgment from the FDIC | June 22, 2021
Letters to US House and US Senate from the National Association of Consumer Advocates (NACA) Signed by Its State Leaders Urging Congress to Rescind OCC Lending Rule
NACA Leaders in 36 States, DC Balk at “Fake Lender” Rule | NACA Press Release, April 27, 2021
Letter to the Senate Committee on Banking from the Conference of State Bank Supervisors (CSBS) supporting the Congressional Review Act challenge to the OCC's fake lender rule
Letter to US Senate Committee on Banking | CSBS, April 26, 2021
"On behalf of the Conference of State Bank Supervisors (CSBS), I am writing to express our members’ support of the Congressional Review Act (CRA) joint resolution (S.J. Res.15) to strike down the Office of the Comptroller of Currency’s (OCC) true lender rule. "
Letter to Speaker Pelosi, Majority Leader Schumer, Minority Leader McCarthy and Minority Leader McConnell re: "Support CRA challenge to OCC 'fake lender' predatory lending rule" | signed by 325 organizations including 13 in AZ
"The undersigned 375 civil rights, community, consumer, faith, housing, labor, legal services, senior rights, small business, and veterans organizations representing all 50 states and the District of Columbia write to urge you to support the Congressional Review Act challenge to the OCC’s final rule, “National Banks and Federal Savings Associations as Lenders,” which will unleash predatory lending in all fifty states."
Letter to US Congress | April 20, 2021
Letter to Governor Ducey from CEI, MIIJ, Wildfire re: Emergency Action Needed to Safeguard CARES Act Deposits from Debt Collectors
Letter to Governor Ducey | CEI, MIJ, Wildfire, April 14, 2020
Press Release | CEI, MIJ, Wildfire, April 15, 2020
Coalition letter to AZ Attorney General Brnovich and Governor Ducey re: Protecting Consumers in Covid-19 Crisis
Letter to AG Brnovich and Governor Ducey | CEI, April 13, 2020
Coalition letter to Governor Ducey and the AZ Dept. of Financial Institutions re: Financial Protections for Consumers During COVID-19
Letter to Governor Ducey and AZDFI | CEI, April 3, 2020
Letter from CEI to AZ Attorney General and the Dept of Insurance and Financial Institutions (DIFI) re: federal and state actions on Rent-A-Bank lending, and requesting action to enforce Arizona's Consumer Lender usuary law cap and consumer protections
"We view the combination of the OCC’s and FDIC’s recent “valid when made” rule and the OCC’s proposed “true-lender” rule as a direct threat to your authority to enforce Arizona laws against predatory lending by nonbank lenders. We are disappointed that the Office of Attorney General and the Department of Insurance and Financial Institutions did not intervene on behalf of Arizona consumers in either rent-a-bank docket at the OCC or the “valid when made” docket at the FDIC as we requested in our January 15, 2020 letter to you."
CEI Letter to AZ AG and DIFI | September 23, 2020
Coalition letter to the Office of the Comptroller of the Currency (OCC) opposing a "True Lender" proposed rule which would allow Rent-A-Bank schemes
"The undersigned Arizona community, consumer, civil rights, faith and nonprofit organizations write to strongly oppose the OCC’s proposed rule 'National Banks and Federal Savings Associations as Lenders.' This rule, if enacted, would nullify Arizona’s usury law which protects consumers from predatory lending at usurious rates."
"Adopting this rule will throw the doors open to rent-a-bank lending in Arizona at interest rates that far exceed our Consumer Lender law usury cap."
Coalition letter to OCC | September 3, 2020
Submitted with CEI's Comments on Proposal “National Banks and Federal Savings Associations as Lenders”
>>> Reference: OCC Docket ID: OCC-2020-0026 "National Banks and Federal Savings Associations as Lenders" <<<
Letter to U.S. Senate Leadership re Consumer Protections for next COVID-19 Legislation
"The 92 undersigned consumer, civil rights, community, housing, labor, and other public interest organizations write to urge you to include consumer protections in the next coronavirus recovery package or other upcoming COVID-19 legislation."
Letter signed by CEI and 91 other public interest organizations | August 12, 2020
Letter from CEI to AZ Attorney General and Arizona Department of Financial Institutions (AZDFI) requesting action to protect Arizona families from Rent-A-Bank schemes
"To the best of our knowledge, no investigations have been opened into the online lenders that are currently marketing their high-cost loans to Arizona consumers in violation of Arizona law and no publicly announced supervision or enforcement actions have been taken."
Updated CEI Letter to AZ AG and AZDIFI | July 15, 2020
CEI Letter to AZ AG and AZDFI | June 19, 2020
National Letter to U.S. Senate and Sen. Banking Committee re: Support debt collection provisions of HEROES Act to give small businesses, nonprofits and consumers a path to recovery
Coalition letter to members of the Arizona Congressional Delegation urging support for a 36% Federal Usury Cap
Letter from CEI, MIJ, Wildfire to Governor Ducey re: Garnishments in COVID-19 Crisis
"Arizonans urgently need you to take executive action to protect the deposited federal CARES Act funds in consumers’ bank accounts from being diverted by debt collectors and creditors instead of being available to spend for emergency family needs. Federal payments to families have already started and we know of no action taken in Arizona to protect these funds."
Letter to Governor Ducey from CEI, MIJ, Wildfire | April 14, 2020
Coalition letter to Attorney General Brnovich re: Protecting Consumers in Covid-19 Crisis
"Thank you for your early leadership to protect consumers in the financial services market and to warn of scams and fraud likely to proliferate during the current crisis. While we appreciate the Arizona effort to stop evictions and mortgage foreclosures, our focus is on protecting low-and-moderate income consumers who are unbanked and underbanked and who use high-cost credit products."
Coalition letter to Attorney General Brnovich | April 13, 2020
A reply from the Office of Attorney General | April 21, 2020
Coalition letter to Governor Ducey re: Financial Protections for Consumers During COVID-19
"The coronavirus poses many interconnected challenges and we applaud your office for recent actions designed to protect the health and safety of vulnerable Arizonans. In addition to your recent actions, we are asking you to provide guidance to the Department of Financial Institutions to ensure that licensee practices in this difficult time support the wellbeing of Arizona consumers and their families."
Coalition letter to Governor Ducey | April 3, 2020
Coalition Comments on FDIC Notice of Proposed Rulemaking, Federal Interest Rate Authority, 12 CFR Part 331, RIN-3064-AF21
Arizona consumer, community and public interest organizations signed below write to strongly oppose the FDIC’s “federal interest rate authority” proposal.
Coalition letter to FDIC | February 4, 2020
Coalition letter to Attorney General Brnovich and AZDFI Superintendent Schraad re: Rent-a-Bank Online Lending in Violation of Arizona Consumer Protections
"We write to request your leadership in enforcing Arizona’s Consumer Lender law and usury cap with online out-of-state lenders that claim to be exempt from your jurisdiction by laundering their loans through banks to make loans at triple-digit rates. High-cost lending harms the economy, traps families in debt, and undermines fair competition with licensed lenders that follow the law."
Coalition letter to AG and AZDFI | January 15, 2020
See our 2018-2019 Letters here