From the comment:
Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its lowincome clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of FinWise Bank. FinWise Bank helps several nonbank lenders make predatory loans at rates up to 160% annual percentage rate (APR) that they cannot legally make directly. The loans that FinWise facilitates are not only usurious; they also pose a host of other consumer protection problems and potential legal violations.
This comment letter focuses on three of FinWise Bank’s partners: American First Finance, Elevate Credit, Inc. (making installment loans through its brand Rise Credit), and Opportunity Financial (“OppFi”). These FinWise partners make loans with rampant problems, including unaffordable APRs, high default rates, debt collection abuses, credit reporting errors, and loans made as a result of identity theft.