From the introduction to the comment:
Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low income clients), Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of Transportation Alliance Bank (dba TAB Bank). TAB Bank serves as a rent-a-bank, nominally originating predatory loans at rates up to 189% APR for Duvera Billing Services, dba EasyPay Finance, to help EasyPay evade state interest rate laws. An analysis of complaints about EasyPay loans raise serious concerns about extensive consumer harm and potential violations of federal and state consumer protection statutes. Given the information presented, the undersigned request that FDIC downgrade TAB Bank on its Community Reinvestment Act Exam.