Threats to Consumers in the Update to the Uniform Interagency Consumer Compliance Rating System

The undersigned Center for Responsible Lending (CRL) and National Consumer Law Center, on behalf of its low income clients (NCLC), write to comment on the update to the Uniform Interagency Consumer Compliance Rating System (CC Rating System) by highlighting three areas of particular concern:

1. Overdraft practices
2. Loans with a total cost of credit exceeding 36% annual percentage rate (APR)
3. Bank partnerships with non-bank lenders whereby non-banks make loans they could not independently make under state law – i.e., rent-a-bank schemes

The CC Rating System is right to emphasize harm to consumers. The above areas, given their capacity to inflict significant consumer harm and to undermine state laws designed to prevent such harm, merit heightened consideration in any review of compliance with consumer protection and civil rights laws.