Broad Coalition Opposes Proposal to Delay CFPB Payday Rule

The Consumer Financial Protection Bureau (CFPB) has proposed delaying when payday lenders would need to comply with a 2017 rule on predatory payday lenders by 15 months. This would allow the industry to skip the common-sense requirement that it verify that a borrower has the ability to repay a loan – and to continue trapping Americans in vicious cycles of debt. Today, the Stop The Debt Trap campaign announced that a broad coalition of more than a hundred organizations from across the country, including consumer, faith, and civil rights groups, has submitted an official comment to the CFPB, opposing delay of the rule. Full text of the comment letter is linked here.

The coalition’s letter states, in part:

“The Bureau’s proposal misguidedly downplays the harm to consumers of spending fifteen more months in the debt traps created by payday and vehicle title loans made without a determination of ability-to-repay. The Bureau correctly points out that its proposed delay will prolong consumers’ exposure to the devastating effects of reborrowing and defaulting on these loans.  But despite identifying these harms, the Bureau troublingly concludes that the financial benefit to industry participants in pushing back compliance with the 2017 Final Rule, and allowing their abusive practices to continue, outweighs the detriment to consumers.

“The Bureau’s proposal is especially concerning given that the 2017 Final Rule itself identified the harmful consequences associated with reborrowing or defaulting on covered loans made without an ability-to-repay determination, or having to put off necessary expenses in order to pay an unaffordable loan made without such a determination. These include loss of a consumer’s only reliable transportation to repossession, the inability to meet critical expenses like rent, utilities, or medicine as a result of unaffordable payments, and illegal and psychologically harmful debt-collection tactics.

“Despite being glossed over in the Bureau’s current proposal, these problems are still as real and as harmful as they were when the 2017 Final Rule was promulgated—a fact that the Bureau has not disputed. Consumers cannot afford to wait fifteen more months for the relief provided by the Rule’s Mandatory Underwriting Provisions.”


On February 6, 2019, the Consumer Financial Protection Bureau proposed to delay the August 19, 2019 compliance date for the Mandatory Underwriting Provisions of the 2017 Final Rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans (2017 Final Rule or Rule) for 15 months. Yesterday was the deadline for comments to be submitted on this delay.

The CFPB also proposed gutting the substance of the 2017 payday rule. The deadline for comments on that proposal is May 15th.


Stop The Debt Trap is a coalition of civil rights, consumer, labor, faith, veterans, seniors and community organizations from all 50 states who committed to ending payday loan debt traps