Civil rights and consumer advocacy organizations urge the Federal Reserve Board to deny an application to become a bank holding company, submitted by Enova, raising particular concern about the effects of its predatory lending on communities of color. This nonbank lender has disproportionate number of complaints from majority-minority communities, charges triple-digit interest rates, has charge-off rates (a measure of defaults) above 50%, and repeatedly violated consumer law, including through unauthorized charges to customers and evading state interest rate caps.