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These comments are from the Texas Fair Lending Alliance (TFLA) and Faith Leaders for Fair Lending — Texas Appleseed is a member of TFLA. Background: Comments on proposed rulemaking on payday, vehicle title, and certain high-cost installment loans. There are three attachments after the comments: 1) Borrower Stories Submitted to TFLA 2) City & County Ordinances/Resolutions 3) Additional Borrower Stories. Docket Number CFPB-2016-0025 or RIN 3170-AA40. Opening Paragraph: Dear Director Cordray, Thank you for the opportunity to submit comments on the CFPB's proposed rule on payday, vehicle title, and certain high cost installment loans. The rule will certainly help to end the harms these loans inflict on communities across the state; however, to ensure that it ends the cycle of debt so many borrowers experience, we urge the CFPB to clarify and strengthen the rule. The cycle of ongoing debt that is too common in Texas’ payday and auto title loan market hurts the financial stability of working families, seniors, and military families and drains charitable and public resources from our communities.
In the consumer lending industry in Texas, almost all contracts for payday and auto title loans have an arbitration agreement that borrowers are required to sign to apply for a loan. Most contracts also include a ban on class actions; some include other provisions such as limits on available damages or waivers to jury trials. Given the flaws inherent to the arbitration system outlined in this comment and the ability of class action lawsuits to remedy harms and incentivize better practices, Texas Appleseed supports ensuring class action lawsuits are available to consumers by preventing companies from banning them through pre-dispute arbitration agreements. See comment for more >>
Texas Appleseed comments to the Consumer Financial Protection Bureau (CFPB) RE: Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z). Docket No. CFPB–2014–0031. RIN 3170–AA22. Texas Appleseed supports the Bureau of Consumer Financial Protection’s (“the Bureau”) proposed amendments to amend Regulation E (implementing the Electronic Funds Transfer Act), Regulation Z (implementing the Truth in Lending Act (“TILA”)) and the official interpretations to the regulations to create comprehensive consumer protections for prepaid financial products. Prepaid debit cards are one of the fastest-growing types of payment instruments in the United States; bringing their regulation in line with that of other, more established payment instruments is a necessary step in making sure that this high-growth industry does not become defined by predatory fee-generating practices.
Texas Appleseed complaint to the Consumer Financial Protection Bureau (CFPB), Office of the Texas Attorney General, the Federal Trade Commission (FTC), and the Texas Office of Consumer Credit Commissioner (OCCC) urging them to take action to end the practice of payday loan businesses filing criminal complaints against borrowers as a debt collection tool.

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