October 5, 2016 | Access to Credit
Alexandria, Va. –The Community Financial Services Association of America (CFSA) anticipates that more than one million concerned Americans will have spoken out against the CFPB’s proposed short-term credit rule during the comment period that ends October 7. In late September, Director Cordray said the CFPB had received over 500,000 comments on its rule proposal – a record-breaking number – and it appears that this number will double before the close of the official comment period. The CFPB now faces a massive backlog of public comments that must be uploaded to the Regulations.gov comment portal and reviewed before the Bureau can begin deliberations on the proposed rule.
“The staggering number of comments submitted to the CFPB has stunned even those of us who already know how much customers value access to small-dollar loan products,” said Dennis Shaul, CFSA CEO. “The CFPB must quickly move to address this backlog of public comments and each comment to the CFPB must be reviewed before the Bureau can begin its deliberations on this rule, regardless of when they were uploaded.”
It may be months before the exact number is officially disclosed, but CFSA projects that over one million customers will have spoken out against the CFPB’s proposed rule through comment letters and petitions submitted to the comment portal, based on conversations with member companies and numerous stakeholders involved in the CFPB comment period.
As a result of the unprecedented input the CFPB has received, it now faces a massive backlog in its comment portal. Presently, only 89,919 comments are publicly accessible on the Bureau’s Regulations.gov comment portal. According to Director Cordray’s estimates, this indicates a backlog of at least 410,000 comments that the CFPB must account for. Using CFSA’s projection of at least one million customers having voiced opposition to the rule, the backlog would be more than 910,000.
CFSA member companies provided their customers with opportunities to make their voices heard. Customers, in turn, overwhelmingly chose to engage in this process, many of them in personal, unique handwritten letters.
“We fully expect that critics are going to attack these engaged customers and come up with far-fetched theories to try to undermine their comments because these special interest groups refuse to accept that so many people value these loans and use them responsibly,” said Shaul. “With more than a million customers expressing concern about the rule, it’s clear that these groups are completely out of touch with the people they claim to represent.”
Once the CFPB addresses this comment backlog and provides Americans the access to all public comments that they deserve, the Bureau is also required to carefully review all comments prior to any further deliberations on the proposed rule. The Bureau has said it will do this, according to a statement that notes it will “carefully consider all comments it receives as it moves towards crafting a final rule.”
The number of comments submitted to the Bureau highlights the extent to which customers value their access to short-term credit. The message that these comments are sending is clear: not only do people depend on short-term credit to bridge financial gaps, customers strongly object to a government agency intruding into their own financial decisions. These comments will allow the CFPB to finally understand the negative impact this proposed rule will have.
In an effort to monitor the CFPB’s progress in addressing the backlog and examine the overwhelming number of customer comments opposing the CFPB’s proposed rule, CFSA has launched CFPBCommentWatch.com. This website will serve as a tool for stakeholders and the media to easily monitor the CFPB’s progress in clearing the backlog of public comments and uploading all comments for public viewing, as well as to ensure that the Bureau listens to the outpouring of customer voices on this rule.
“The CFPB has the moral and legal obligation to thoroughly review all comments as required by law. We will make sure it is held fully accountable if it does not,” warned Shaul. “We will be watching closely to make sure the CFPB quickly addresses this backlog and finally considers the opinion of customers in its deliberations.”
About the Community Financial Services Association of America
The Community Financial Services Association of America is the only national organization dedicated solely to promoting responsible regulation of the small-dollar lending industry and consumer protections through CFSA's Best Practices. As such, we are committed to working with policymakers, consumer advocates, and CFSA member companies to ensure that small-dollar loans are a safe and viable credit option for consumers.