YOU HAVE NO RIGHT TO CALL YOUR REPEAL "CONSUMER PROTECTION"!

COMMENT BY MAY 15 against repealing THE PAYDAY LOAN RULE!

I left the following Comments with the current Consumer Financial Protection Bureau earlier today in opposition to repeal of the Payday Loan Rule.  Tomorrow is the deadline for your own Comments to be heard!  The contact information is all set out in my own Comments, below.

 

May 14, 2019

Consumer Financial Protection Bureau

Online at:  https://www.regulations.gov

Re:    Payday, Vehicle Title, and Certain High-Cost Installment Loans;

          Proposal to Rescind or Repeal the "Payday Loan Rule."

          Docket No. CFPB-2019-0006

          RIN 3170-AA80

To the Director of the Consumer Financial Protection Bureau:

Your assertion that it is too expensive to research the evidence is contrary to established administrative law and will not validly support your proposed rescission of the Payday Loan Rule.

          Your assertion is more than misleading.  It is downright false.

          It is clear that the current CFPB does not care about developing evidence at all in this proposal.  You have made no effort to support your proposal with new evidence.  The 47 printed pages of your proposal in the Federal Register is about 10% of the Payday Loan Rule and the evidence supporting it.  The Rule was printed at 449 pages in the Federal Register.  Its supporting evidence was sourced in 1,315 notes.

          Instead of evidence you are offering a different judgment based on the same evidence.  You offer only conclusions.  You do not provide evidence. 

          In the end, you may have the right to repeal the Payday Loan Rule.  But you have no right to call your repeal "Consumer Protection."

          Thank you for your consideration.

Sincerely Yours,

Dennis Wall

 

Please Read The Disclaimer.  ©2019 Dennis J. Wall.  All Rights Reserved.