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: Overdraft practices Loans with a total cost of credit exceeding 36% annual percentage rate (APR) 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...