Consumer advocates largely supported the CFPB’s framing of abusive practices. They called for tightening up some areas of the policy, including how the CFPB views a company’s intent when determining whether it’s taking “unreasonable advantage” of a consumer. “The policy statement recognizes that ‘intent is not a required element to show material interference’ but the Statement is not explicit on this point when it addresses acts or practices that take ‘unreasonable advantage’ of consumer vulnerabilities,” the Center for Responsible Lending said in a comment letter.
