Stop The Debt Trap Coalition Letter Opposing Congressional Repeal of the Payday Rule

March 1, 2018


Dear Members of Congress,

The undersigned organizations urge your office to oppose H.J. Res. 122. This measure would repeal the Consumer Financial Protection Bureau’s (Consumer Bureau) payday rule, which curbs the ability of payday and car-title lenders to trap consumers in an endless cycle of 300% interest debt. It is imperative that Congress oppose any effort to repeal or block the rule’s protections against the payday lending debt trap, which often result in financial ruin.

At its core, the rule is based on the common-sense principle that lenders have a responsibility to determine whether a borrower has the ability to repay their loan without getting stuck in a cycle of unaffordable debt. This principle is particularly important for these highcost loans where lenders require the power to seize a borrower’s bank account or car. An ability-to-repay requirement is a sensible and sound approach and a principle that, according to a recent poll of likely voters, more than 70% of Republicans, Independents, and Democrats support.

This rule is the culmination of over five years of stakeholder input and extensive research showing clear evidence of the harm caused by making these loans without regard to abilitytorepay. A large body of research has demonstrated that payday and car title loans are structured to create a long-term debt trap that drains consumers’ bank accounts and causes significant financial harm, including delinquency and default, overdraft and non-sufficient funds fees, increased difficulty paying mortgages, rent, and other bills, loss of checking accounts, and bankruptcy. The lack of underwriting for ability-to-repay, high fees, and access to a borrower’s checking account or car title enables lenders to repeatedly flip borrowers from one unaffordable loan to another. A large portion of borrowers eventually default, but often not before paying hundreds or even thousands of dollars in fees.

This is why the payday rule is necessary—to help ensure that lenders cannot trap borrowers—who are typically already significantly financially distressed—in a debt trap that leaves them only worse off. Repealing this rule would leave veterans, seniors, and communities of color at particular risk, because they are often targeted by payday lenders who trap them in unaffordable high-cost loans. Additionally, the CRA measure would prevent the CFPB from issuing a similar rule in the future.

While 15 states plus the District of Columbia cap state interest rates at 36% or less, which is the most effective protection against the payday lending debt trap, the Consumer Bureau’s rule provides critical protection in the 35 states that still permit these unaffordable debt trap loans.

H.J. Res. 122, by repealing the Consumer Bureau’s common sense rule, would give payday lenders a free pass to continue exploiting financially vulnerable Americans. We urge you to stand against predatory lenders by voting against this measure.




American Federation of State, County, and Municipal Workers (AFSCME)

Americans for Financial Reform

Allied Progress

Asset Building Strategies

Bend the Arc Jewish Action

Consumer Action

Communications Workers of America

Consumers Union

Consumer Federation of America

Daily Kos


Ecumenical Poverty Institute

EMC Strategies

Franciscan Action Network

International Union, United Automobile, Aerospace and Agricultural Implementation Workers of America (UAW)

Interfaith Center for Corporate Responsibility

The Leadership Conference on Civil and Human Rights

Local Initiatives Support Corporation (LISC)

Mi Familia Vota


National Advocacy Center of the Sisters of the Good Shepherd

National Association of Consumer Advocates

National Association of Previous Prisoners, Inc.

National Association of Social Workers

National CAPACD (Coalition for Asian Pacific American Community Development)

National Community Investment Fund

National Community Reinvestment Coalition (NCRC)

National Consumer Law Center (on behalf of its low-income clients)

National Fair Housing Alliance (NFHA)

National Partnership for Women & Families

People’s Action Institute

Prosperity Now

Provincial Council Clerics of St. Viator

Public Citizen

Public Justice

The Rootstrikers Project at Demand Progress

Sargent Shriver National Center on Poverty Law

Sisters of Mercy South Central Community

Southern Poverty Law Center

TURN-The Utility Reform Network


Union for Reform Judaism


Woodbury Fund


9to5, National Association of Working Women



ACLU of Alaska

Alaska Community Development Corporation

AK Children’s Trust


Northern Justice Project



Arkansans Against Abusive Payday Lending



Arizona Coalition to End Sexual and Domestic Violence

Arizona Community Action Association

Arizona PIRG (Public Interest Research Group)

A New Leaf-Mesa Community Action Network

Campesinos Sin Fronteras

Center for Economic Integrity

Gila County Community Services Division

Protecting Arizona’s Family Coalition

Southern Arizona Grandparent Association

St. Vincent DePaul Society, Diocese of Tucson

United Way of Tucson and Southern Arizona



California Reinvestment Coalition



The Bell Policy Center

Colorado Center on Law and Policy

Colorado Public Interest Research Group (CoPIRG)

Energy Outreach Colorado

The Interfaith Alliance of Colorado

Lutheran Advocacy Ministry Colorado



Connecticut Association for Human Services

Connecticut Legal Services Inc.



Georgia Watch

Green Forest Community Development Corporation (GFCDC)

Urban Asset Builders



Florida Alliance for Consumer Protection

Jacksonville Area Legal Aid, Inc.



Idaho Community Action Network



Active Alliance Counseling

Bailey’s Café


BIG: Blacks in Green

Center for Changing Lives

Center for Economic Progress

Chicago City Treasurer’s Office

Community Interventions Institute, Inc.

Earthmover Credit Unions

Heartland Alliance

Heartland Human Care Services

Health & Medicine Policy Research Group

Housing Action Illinois


Illinois Building Group

Illinois PIRG

Karen Chan Financial Education & Consulting, LLC

LISC Chicago

Naviance Solutions

Northwest Side Housing Alliance

Peterson Healthcare Consulting, Inc.

Project IRENE


Southwest Organizing Project

Working Families

Woodstock Institute

YMCA Metropolitan Chicago



Advantage Housing, Inc.


Continuum Care Network, NWI Inc.

Cynthia R. Bauer, CPA, CGMA

Edna Martin Christian Center

Fair Housing Center of Central Indiana

Families First Indiana, Inc.

God’s Helping Hand

Habitat for Humanity of Indiana

Habitat for Humanity of Northeast Indiana

Homestead CS

Hoosier Action

Indiana Assets & Opportunity Network

Indiana Association of United Ways

Indiana Catholic Conference

Indiana Friends Committee on Legislation

Indiana Institute of Working Families

Indiana Kentucky Synod of the ECLA

Indianapolis Neighborhood Resource Center

Irvington Development Organization

John Boner Neighborhood Centers

KW Consultants LLC

Legacy Foundation, Inc.

Mary Miles Consulting

The Military/Veterans Coalition of Indiana

Neighborhood Vitalization Corporation

Northwest Indiana Reinvestment Alliance


Prosperity Indiana

Providence Housing Corporation

Reserve Officers Association, Department of Indiana

Thrive Alliance




Labette County Assistance Center



Kentucky Center for Economic Policy

Kentucky Equal Justice Center



Louisiana Budget Project



Maine Center for Economic Policy

Maine People’s Alliance



The Midas Collaborative



Maryland Consumer Rights Coalition

Public Justice Center



Community Economic Development Association of Michigan

Michigan Poverty Law Program



Exodus Lending



Covenant Faith Outreach Ministries



Consumers Council of Missouri

Missouri Faith Voices



AFSCME Montana

Agadas Integrated Wellness

Angela’s Piazza

Billings First Congregational Church UCC

Billings Ground Swell

Bishop, Heenan & Davies Law Firm

Bitter Roo RC & D

Danielle Egnew Spiritual Advisory

Deering For Montana

Emmaus Campus Ministry

Fit Body Boot Camp Billings

Greater Yellowstone Central Labor Council

Har Shalom Congregation

Harvest House Inc.


IBEW 233

IBEW 768


Montana Fair Housing

Montana Organizing Project

Montana Trial Lawyers

Morrison, Sherwood, Wilson & Deola PPLP

MT-NWY Conference UCC

Neighborhood Works Montana

Royal Realty Co.

Rural Dynamic Inc.

Southwestern Montana Central Labor Council

Spa, Reflexology & Acupuncture

St. Paul Lutheran Church

Swift Building Lofts

University Congregational Church, UCC

Yellowstone County Democratic Central Committee



Voices for Children in Nebraska


North Carolina

Action NC

Alexander County Habitat for Humanity

Asheville Habitat for Humanity

Atkinson Collaborative Enterprise

Bonnie Wright and Associates

BPFNA-Bautistas por la Paz

CCCS of Greater Greensboro

CCCS of WNC, Inc. DBA OnTrack Financial Education & Counseling

Cedar Grove Institute for Sustainable Communities

Centre for Homeownership and Economic Development

Chatham Habitat for Humanity

The Collaborative of NC

Community Empowerment Fund

Community Management Corporation

Ecusta Credit Union

Elizabeth City Habitat for Humanity

Episcopal Diocese of North Carolina

Fayetteville Area Habitat for Humanity

Financial Pathways of the Piedmont

Habitat for Humanity of Catawba Valley

Habitat for Humanity of Forsyth County

Habitat for Humanity of Greater Greensboro

Habitat for Humanity of Lincoln County, NC

Habitat for Humanity of North Carolina, Inc.

Henderson County Habitat for Humanity

Mitchell-Yancey Habitat for Humanity

Navy-Marine Corps Society at Camp Lejeune


NC A. Philip Randolph Educational Fund, Inc.

NC A. Philip Randolph Institute

NC Council of Churches

NC National Organization for Women

North Carolina Assets Alliance

North Carolina Coalition on Aging

North Carolina Community Development Initiative

North Carolina Consumers Council

North Carolina Housing Coalition

North Carolina Justice Center

North Carolina Rural Center

Person County Habitat for Humanity

Pisgah Legal Services

Salisbury CDC

SiX Action

Superior Consumer Advocacy Network


Working America NC


North Dakota

Community Action Partnership of North Dakota

Dakota Prairie Community Action Agency

Native American Development Center

North Dakota Chapter of the National Association of Social Workers

North Dakota Economic Security and Prosperity Alliance

North Dakota Women’s Network

Office of Senator Tim Matherm

Sacred Pipe Resource Center


New Jersey

La Case de Don Pedro

New Jersey Citizen Action


Sisters of St. Dominic of Caldwell NJ


New Mexico

Interfaith Worker Justice-New Mexico

Lutheran Advocacy Ministry-New Mexico

The New Mexico Center on Law and Policy

New Mexico Fair Lending Coalition

New Mexico Voices for Children

Tierra del Sol Housing Corporation


New York

Buffalo Urban League

Empire Justice Center

Hebrew Free Loan Society

Long Island Housing Services, Inc.

Mobilization for Justice, Inc.


New Yorkers for Responsible Lending

Tri-State Coalition for Responsible Investment



Policy Matters Ohio



Cathedral of Hope UCC

Church of the Open Arms UCC

Fellowship Congregational UCC

Oscar Romero Catholic Worker House

St. Charles Borromeo Catholic Church

Voices Organized in Civic Engagement (VOICE) Action Fund



Archdiocese of Portland

CASA of Oregon


Rhode Island

Rhode Island Council of Churches


South Carolina

SC Appleseed



Tennessee Citizen Action



BCL of Texas

City Square

First Baptist Church of Crowell

Hispanic Baptist Convention of Texas

Mosaic Fellowship

Texas Fair Lending Alliance

United Way of Greater Houston



Housing Opportunities Made Equal of Virginia

Virginia Citizens Consumer Council

Virginia Organizing

Virginia Poverty Law Center






US Territories

Congregation of Our Lady of the Good Shepherd, US Provinces