This comment was filed in response to the Department of the Treasury’s request for information on marketplace lending. Our history of advocacy for fair lending practices, and against unfair ones, is the lens through which we focus these comments, where we emphasize:
- Online marketplace loans must comply with applicable state law
- Underwriting for ability-to-repay, based on income and expenses, should be required for every loan
- Small business loan protections, including prohibition of broker steering, are critical
- Mandatory arbitration clauses should be prohibited