In a September 3 letter to Acting Comptroller of the Currency, Brian Brooks, the Californians for Economic Justice Coalition wrote:
California has strong interest rate caps on installment loans intended to protect our residents from predatory loans. Understanding that products like payday loans, car-title loans, and high-cost installment loans at sky high interest rates are merely debt traps for borrowers, consumer advocates, community and faith-based organizations, and veterans groups worked closely with legislators and lending industry representatives to reach a final compromise that would prohibit predatory lending and still allow companies to offer loans at competitive rates. This effort, spanning three years of deliberative and thoughtful conversations with a broad coalition of stakeholders, led to the final provisions of AB 539 (Limon), The Fair Access to Credit Act in 2019. The law capped interest rates on loans of $2,500 and above at 36% APR plus the federal funds rate. It became effective January 1, 2020.