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TCH Comments on CFPB Payday Lending Proposal

The Clearing House (TCH) submitted a letter to the CFPB regarding the payment-related provisions of its payday, vehicle title and certain high-cost installment loans proposal (“Proposal”). While The Clearing House generally applauds the Bureau’s efforts to establish protections for certain credit products used by financially vulnerable consumers, TCH requested that the Bureau revise the proposal, to clarify that (i) covered lenders are solely responsible for compliance with the Proposal’s payment presentment and notice requirements, and (ii) depository institutions that provide banking and payment services to covered lenders or consumer borrowers, are not responsible for ensuring such compliance.