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
Letter from CEI to the Arizona Attorney General Re: Align Income Share Funding in Arizona Regulatory Sandbox Program
"Dear Attorney General Brnovich, We urge you to reconsider your decision to admit Align Income Share Funding to participate in the Arizona Regulatory Sandbox Program without requiring the company to comply with Arizona’s usury cap and the other consumer protections in the Consumer Lender law. We respectfully request that you re-examine this financial services firm and upon re-examination, revoke sandbox participation for their Income Sharing Agreement (ISA) product."
CEI Letter to Attorney General Brnovich | Center for Economic Integrity, September 11, 2019
Letter to the editor on CFPB debt collection rule
Local Opinion: Fed. agency needs to live up to its name |By Kelly Griffith Special to the Arizona Daily Star, July 24, 2019
"The Consumer Financial Protection Bureau, the watchdog agency created to protect consumers in the wake of the 2008 financial crisis, recently proposed a rule that does more to protect abusive debt collectors than to protect Arizonans from debt collector misconduct. If the bureau fails to heed advice to strengthen its final rule to rein in abusive debt collection tactics, then it should consider a re-branding. The public can weigh in through Aug. 19."
Letter from the William E. Morris Institute for Justice to AZ Governor Ducey re: Request that Transparency and Public Oversight be an Affirmative Part of the Regulatory Sandbox Program
MIJ Letter to Governor Ducey | June 28, 2019, William E. Morris Institute for Justice
Coalition letter to the Consumer Financial Protection Bureau re: Proposal to Rescind Ability-to-Repay
Coalition letter to the CFPB re: Comments on Proposal to Rescind Ability-to-Repay Requirements Governing Payday, Vehicle title, and Certain High-Cost Installment Loans | May 13, 2019
"Dear Director Kraninger, We are writing on behalf of Arizona consumer and community organizations to oppose the proposal to rescind key protections in the CFPB rule governing payday, car title and some installment loans..."
Letter from CEI to Arizona Governor Doug Ducey with a Request to Veto House Bill 2177
CEI Letter to Governor Ducey "Request for a Veto of House Bill 2177" | Center for Economic Integrity, March 28, 2019
"Arizona’s Regulatory Sandbox Program Creates More Government but Less Consumer Protection"
"HB 2177 fails to close the glaring consumer protection holes in the Sandbox law"
Letter from MIJ to Arizona Governor Doug Ducey with a Request to Veto House Bill 2177
MIJ Letter to Governor Ducey "Request for a Veto of House Bill 2177" | William E. Morris Institute for Justice, March 27, 2019
"The Institute requests that you veto House Bill 2177 and require that the regulatory sandbox program has transparency and public oversight before it is expanded."
Letter to the Consumer Financial Protection Bureau re: proposed No-Action Letter and Product Sandbox proposal
A group of 80 consumer, civil rights, legal services, labor and community groups and environmental groups write in strong opposition to the proposed changes to the Consumer Financial Protection Bureau’s (CFPB or Bureau) no-action letter policy and to the new proposed product sandbox.
Comments on Policy on No-Action Letters and the BCFP Product Sandbox Submitted to the Consumer Financial Protection Bureau
Consumer groups filed comments in the CFPB docket on creating a national “sandbox” for financial services and on drastically changing the CFPB’s No-Action Letter policy. CEI joined NCLC and other national groups in a longer comment that includes a discussion of the Arizona experience so far with our Regulatory Sandbox Program. You can find that section at page 48-53 of the long comment linked below. The CFPB proposal came from Paul Watkins, formerly of the Arizona Office of Attorney General, who led their campaign to create a “sandbox” in Arizona.
Comments submitted to the CFPB | February 11, 2019 >>> Reference: Docket No. CFPB-2018-0042, issued December 13, 2018 <<<
Comments in response to the FDIC's Request for Information on Small-Dollar Lending
Comments in response to the National Credit Union Administration's (NCUA) proposal to expand its payday alternative loan program
CEI Letter to the Secretary of the Board, NCUA | July 30, 2018, Updated August 24, 2018
>>> Reference: Payday Alternative Loans, Proposed Rule, 12 CFR Part 701, RIN 3133-AE84, issued May 24, 2018 <<<
Letter Re: Arizona “Regulatory Sandbox Program” Implementation
Coalition Letter to AZ Attorney General | July 24, 2018 >>> Reference: House Bill 2434, signed 03/22/2018 <<<