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Docket No. CFPB-2019-0006 - Human Rights Watch Comment on CFPB Proposal to Rescind Provisions in the Rule Governing Payday, Vehicle Title, and Certain High-Cost Installment Loans

Dear Ms. Kraninger, We write to express our deep concern with the Consumer Financial Protection Bureau’s (CFPB’s) proposal to rescind certain provisions of the rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans, particularly those provisions requiring an assessment of a possible loan recipient’s ability to pay.[1] The rule’s finalization in 2017 was a significant and necessary step forward in protecting the millions of Americans subject to predatory high interest loans that, by design, often lead low-income borrowers into cyclical debt traps.[2] Now that the time is approaching…

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