The undersigned consumer, civil rights and faith groups write in strong opposition to HR 4861 (Hollingsworth), the Ensuring Quality Unbiased Access to Loans Act of 2018 (EQUAL Act). The bill exempts bank payday loans (also called “deposit advance products”) from the Consumer Financial Protection Bureau’s (CFPB) payday loan rule and also nullifies the Federal Deposit Insurance Corp.’s (FDIC) deposit advance product guidance. The bill would pave the way for banks to return to abusive 200% to 300% APR balloon-payment bank payday loans that trap consumers and seniors on Social Security in a cycle of debt.