Comments in Response to National Credit Union Administration Proposal to Expand its Payday Alternative Loan Program

We thank NCUA for its efforts to protect credit union members from payday loans. In recent years, the number of federal credit unions (FCUs) we are aware of engaging in payday lending, either directly or indirectly through credit union service organizations (CUSOs), has decreased to a single FCU. And through both its regular rules and its PAL program, NCUA has encouraged FCUs to offer small dollar installment loans that can be significantly cheaper than payday loans.

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