July 2, 2020
Payday and Other Small Dollar Loans
Comment Letter
The Center for Responsible Lending (CRL) joined with a coalition of civil rights, community, consumer, and faith organizations in two public comment letters warning the Federal Deposit Insurance Corporation (FDIC) that its proposed rule for chartering additional underregulated Industrial Loan Companies (ILCs) would expand predatory, high-interest lending. The plan would grant the predominantly online non-bank companies that are approved for an ILC with preemptory powers over state consumer protection laws, including interest rate caps.