CEI Letter in Opposition to Arizona House Bill 2309 - Payday (EWA) Loan Exemption from Arizona’s Consumer Lending Laws
Letter to the Arizona House of Representatives | January 27, 2026
"On behalf of the Center for Economic Integrity, I am writing to voice our strong opposition to Arizona House Bill 2309 (AZ HB2309), with particular concern for the bill’s exemption from fair lending laws, practices and principles across our state."
Reference: Arizona HB2309: earned wage access; providers; license
CEI Comment Letter to the Arizona Department of Insurance and Financial Institutions (AZ DIFI) re: Consumer Lender/Sales Finance Dual License
Comment Letter re: Regulatory Bulletin 2025-04 (DFI) | September 26, 2025
"On behalf of Arizona consumers, The Center for Economic Integrity (CEI) appreciates the opportunity to comment on the question of whether licensed Consumer Lenders are permitted to make loans exceeding $10,000 and, if not, whether such a lender should be able to legally make a loan exceeding $10,000 by obtaining a Sales Finance license to make Secondary Motor Vehicle Finance Transaction loans."
Reference: Regulatory Bulletin 2025-04 (DFI) | "Consumer Lender/Sales Finance Dual License."
National Letter re: Oppose resolution to overturn CFPB overdraft fee rule
Letter to the Committee on Financial Services, U.S. House of Representatives | February 5, 2025
"The undersigned 200 consumer, civil rights, labor, legal services and community organizations and academics write to urge you to oppose efforts to overturn the Consumer Financial Protection Bureau’s overdraft fee rule, which will reduce most overdraft fees from $35 to $5, stop manipulative practices by big banks, improve transparency, and put $5 billion back into the pockets of everyday people and their families. The public widely views current overdraft fee practices as unfair."
Letter from ~90 organizations to Senators and Members of Congress re: the Consumer Financial Protection Bureau's finalized rule on Credit Card Late Fees
Letter requesting opposition to overturning the CFPB's rule on credit card late fees | April 15, 2024
"We, the undersigned 90 national, state, and local organizations, strongly oppose any attempts by lawmakers to overturn the Consumer Financial Protection Bureau's (CFPB) finalized rule on credit card late fees.Simply put, opposing this Biden Administration reform will result in higher credit card fees for working families. This rule is a critical step toward protecting Americans from excessive and unjustified financial burdens imposed by credit card companies."
Letter from the Society of St. Vincent De Paul Tucson Diocesan Council to AZ State Senate Finance and Commerce Committee re: Earned Wage Access bill
Letter requesting NOT to pass bill SB 1273: earned wage access; providers; license | February 14, 2024
"The Society of St. Vincent de Paul of Southern Arizona strongly opposes SB 1273, well knowing that those who might be tempted to borrow on such predatory terms are usually the most vulnerable and desperate within our population. These products have no useful place in Arizona, not for the working poor nor anyone else. Why would anyone with an acceptable credit rating borrow under such usurious conditions?"
Transparency re: Arizona's Regulatory Sandbox
Letter of reply to CEI and MIJ from the AZ OAG | July 19, 2023
In response to a Letter to the OAG from CEI and MIJ | February 23, 2023
"Re: Public Records Requests Office of Attorney General and Department of Insurance and Financial Institutions"
National Letters re: Banks Engaged in Predatory "Rent-A-Bank" lending
National comment letter to FDIC re Capital Community Bank, March 30, 2023
National comment letter to FDIC re Republic Bank and Trust, March 30, 2023
National comment letter to KY DFI re Republic Bank and Trust, March 30, 2023
National comment letter to UT DFI re Capital Community Bank, March 30, 2023
All associated with a NCLC Press Release | March 30, 2023
Letter to the Arizona Attorney General re: Request to rescind Arizona Attorney General Office Opinion Letter regarding Earned Wage Access Products
Letter signed by CEI, MIJ, NCLC, and Wildfire | January 24, 2023
Letter from CEI to the CFPB requesting an investigation into payday loan lookalike "registration" loans
Letter signed by CEI to the CFPB | September 16, 2022
"We write to urge the Consumer Financial Protection Bureau to investigate Arizona licensed Sales Finance companies that are making payday loan lookalike “registration” loans under the title loan law instead of as Consumer Lenders under Arizona’s usury law to determine compliance with the Consumer Financial Protection Act."
See our 2020-2021 Letters here
See our 2018-2019 Letters here