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 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 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 325 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 | March 22, 2021
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
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 <<<