[House Report 115-890]
[From the U.S. Government Publishing Office]


115th Congress    }                                  {         Report
                        HOUSE OF REPRESENTATIVES
 2d Session       }                                  {         115-890

======================================================================



 
         ENSURING QUALITY UNBIASED ACCESS TO LOANS ACT OF 2018

                                _______
                                

 August 3, 2018.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

                                _______
                                

Mr. Hensarling, from the Committee on Financial Services, submitted the 
                               following

                              R E P O R T

                             together with

                             MINORITY VIEWS

                        [To accompany H.R. 4861]

      [Including cost estimate of the Congressional Budget Office]

    The Committee on Financial Services, to whom was referred 
the bill (H.R. 4861) to nullify certain guidance on deposit 
advance products, to require the Federal banking agencies to 
establish standards for short-term, small-dollar loans made by 
insured depository institutions, to exempt insured depository 
institutions and insured credit unions from the payday lending 
rule of the Bureau of Consumer Financial Protection, and for 
other purposes, having considered the same, report favorably 
thereon without amendment and recommend that the bill do pass.

                          PURPOSE AND SUMMARY

    Introduced by Representative Trey Hollingsworth on November 
16, 2017, H.R. 4861, the ``Ensuring Quality Unbiased Access to 
Loans Act of 2018'' would repeal the Federal Deposit Insurance 
Corporation's (FDIC) ``Guidance on Supervisory Concerns and 
Expectations Regarding Deposit Advance Products'' (78 Fed. Reg. 
70552; November 26, 2013). The bill would also require each 
Federal banking agency to issue regulations, subject to notice 
and comment, to establish standards for short-term, small-
dollar loans or lines of credit made available by insured 
depository institutions.

                  BACKGROUND AND NEED FOR LEGISLATION

    As early as 1995, many financial institutions offered small 
dollar loans to customers as an alternative to other short-term 
lending products known as ``deposit advance products.'' These 
loans were typically only available to existing customers with 
direct deposit and provided a short term line of credit for the 
customer. Institutions offering the product charged a fee in 
terms of dollars per amount advanced and included limits on 
advances. The outstanding balance is repaid from the consumers 
direct deposits; however, the financial institution could offer 
the consumer an extended repayment plan. Many of these products 
included ``cooling off'' periods that prohibited consumers from 
accessing another deposit advance.
    In 2012 the Center for Financial Services Innovation 
conducted a survey of consumer's use of small dollar credit 
products, including deposit advance.\1\ This survey found that 
53% of respondents would use deposit advance again without 
hesitation, and overall 90% of respondents rated their 
satisfaction with the product as 3 or higher (based on a scale 
of 1 to 5). Furthermore, the survey found that the costs of 
deposit advance products were least likely to exceed consumers' 
expectations compared to other small dollar credit products.
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    \1\https://s3.amazonaws.com/cfsi-innovation-files/wp-content/
uploads/2017/01/31163518/A-Complex-Portrait-An-Examination-of-Small-
Dollar-Credit-Consumers.pdf.
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    On November 21, 2013, the Federal Deposit Insurance 
Corporation (FDIC) and the Office of the Comptroller of the 
Currency (OCC) issued final guidance to financial institutions 
that offered deposit advance products.\2\ The guidance includes 
the following requirements:
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    \2\https://www.fdic.gov/news/news/press/2013/pr13105a.pdf.
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     For the bank to be able to evaluate a customer's 
deposit advance eligibility, the customer must have had a 
deposit account with the bank for at least six months.
     Customers with any delinquent or adversely 
classified credits should be ineligible.
     The bank should analyze the customer's financial 
capability, giving consideration to the customer's ability to 
repay a loan without needing to borrow repeatedly from any 
source, including re-borrowing, to meet necessary expenses.
     Each deposit advance loan should be repaid in full 
before a subsequent loan is made, banks should not offer more 
than one loan per monthly statement cycle, and a cooling-off 
period of at least one monthly statement after repayment of a 
loan should be completed before another loan is made. We read 
these requirements to effectively impose a limit of six deposit 
advances per year.
     A customer's deposit advance credit limit should 
not be increased without a full underwriting assessment and any 
increase should not be automatic but should be initiated by a 
customer's request.
     The bank should reevaluate the customer's 
eligibility and capacity for the product no less often than 
every six months and identify risk that could negatively affect 
the customer's eligibility, such as repeated overdrafts.
    Although the guidance from the respective banking agencies 
does not specifically ban deposit advance products, its effect 
on banks makes it impossible to continue offering these 
products on a large-scale basis, if at all. This is 
accomplished by asserting that certain risks are associated 
with the products including credit, reputation, operational, 
and compliance risk. In a press statement announcing the 
release of the guidance, then Comptroller Thomas Curry stated:

        ``The OCC encourages banks to offer responsible 
        products that meet the small-dollar credit needs of 
        customers . . . However, deposit advance products share 
        a number of characteristics with traditional payday 
        loans, including high fees, short repayment periods, 
        and inadequate attention to the ability to repay. As 
        such, these products can trap customers in a cycle of 
        high-cost debt that they are unable to repay. As a 
        result, they pose significant safety and soundness and 
        consumer protection risks. Banks must understand and 
        manage those risks, and this guidance clarifies our 
        expectations for doing so.''\3\
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    \3\https://www.occ.treas.gov/news-issuances/news-releases/2013/nr-
occ-2013-182.html.

    As a result of the 2013 guidance, financial institutions 
that previously chose to offer deposit advance products 
discontinued doing so, to the extent that only one FDIC-insured 
institution currently offers a deposit advance product.
    Despite effectively banning deposit advance products by 
dis-incentivizing banks to offer them, the demand remains, and 
in many cases will only intensify in the wake of the Bureau of 
Consumer Financial Protection (BCFP) issuing a Final Rule to 
regulate short-term small-dollar loans. The BCFP rule, released 
on October 5, 2017, affects loans where the consumer must 
substantially repay within 45 days, in large lumps, or any loan 
where the cost of credit exceeds 36 percent per year 
(effectively applying an inappropriate Annual Percentage Rate 
calculation to loans that are intended to be held for only a 
short period).
    The same day the BCFP released its final rule, then-Acting 
Comptroller Keith Noreika rescinded the OCC guidance on deposit 
advance products. According to Mr. Noreika:

        The continuation of the OCC's guidance would subject 
        national banks and federal savings associations to 
        potentially inconsistent regulatory direction and undue 
        burden as they prepare to implement the requirements of 
        the CFPB's final rule. Moreover, in the years since the 
        agency issued the guidance, it has become clear to me 
        that it has become difficult for banks to serve 
        consumers' need for short-term, small-dollar credit. As 
        a result, consumers who would rely on highly regulated 
        banks and thrifts for these legitimate and well-
        regulated products to meet their financial needs turn 
        to other, lesser regulated entities, which may result 
        in consumer harm and expense. In ways, the guidance may 
        even hurt the very consumers it is intended to help, 
        the most marginalized, unbanked and underbanked 
        portions of our society.''\4\
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    \4\https://www.occ.treas.gov/news-issuances/news-releases/2017/nr-
occ-2017-118.html.

    A result of the heavy federal regulation of the short-term, 
small dollar credit is the potential elimination of the entire 
marketplace, leaving consumers experiencing financial 
emergencies with no safe options for short-term, small-dollar 
credit. By repealing the FDIC guidance, and requiring future 
regulation to be transparently evaluated and coordinated 
between banking regulators, banks will have the legal and 
regulatory certainty to re-enter the marketplace and re-
introduce these products, which will give consumers more credit 
options from which to choose in an emergency.

                                HEARINGS

    The Subcommittee on Financial Institutions held a hearing 
examining matters relating to H.R. 4861 on July 12, 2017.

                        COMMITTEE CONSIDERATION

    The Committee on Financial Services met in open session on 
March 21, 2018 and ordered H.R. 4861 to be reported favorably 
to the House without amendment by a recorded vote of 34 yeas to 
26 nays (recorded vote no. FC-167), a quorum being present.

                            COMMITTEE VOTES

    Clause 3(b) of rule XIII of the Rules of the House of 
Representatives requires the Committee to list the record votes 
on the motion to report legislation and amendments thereto. A 
recorded vote was taken on an amendment offered by Rep. 
Ellison. The amendment was not agreed to by a vote of 26 yeas 
to 33 nays (Record vote no. FC-166). A recorded vote was taken 
on a motion by Chairman Hensarling to report the bill favorably 
to the House without amendment. The motion was agreed to by a 
recorded vote of 34 yeas to 26 nays (Record vote no. FC-167), a 
quorum being present.




[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]





                      COMMITTEE OVERSIGHT FINDINGS

    Pursuant to clause 3(c)(1) of rule XIII of the Rules of the 
House of Representatives, the findings and recommendations of 
the Committee based on oversight activities under clause 
2(b)(1) of rule X of the Rules of the House of Representatives, 
are incorporated in the descriptive portions of this report.

                    PERFORMANCE GOALS AND OBJECTIVES

    Pursuant to clause 3(c)(4) of rule XIII of the Rules of the 
House of Representatives, the Committee states that H.R. 4861 
will repeal the FDIC's guidance on Deposit Advance Products 
which will allow customers who might not qualify for 
traditional credit products such as credit cards and lines of 
credit to have access to deposit advance products as an 
additional funding option, from financial institutions which 
they have an established relationships at.

   NEW BUDGET AUTHORITY, ENTITLEMENT AUTHORITY, AND TAX EXPENDITURES

    In compliance with clause 3(c)(2) of rule XIII of the Rules 
of the House of Representatives, the Committee adopts as its 
own the estimate of new budget authority, entitlement 
authority, or tax expenditures or revenues contained in the 
cost estimate prepared by the Director of the Congressional 
Budget Office pursuant to section 402 of the Congressional 
Budget Act of 1974.

                 CONGRESSIONAL BUDGET OFFICE ESTIMATES

    Pursuant to clause 3(c)(3) of rule XIII of the Rules of the 
House of Representatives, the following is the cost estimate 
provided by the Congressional Budget Office pursuant to section 
402 of the Congressional Budget Act of 1974:

                                     U.S. Congress,
                               Congressional Budget Office,
                                     Washington, DC, June 20, 2018.
Hon. Jeb Hensarling,
Chairman, Committee on Financial Services,
House of Representatives, Washington, DC.
    Dear Mr. Chairman: The Congressional Budget Office has 
prepared the enclosed cost estimate for H.R. 4861, the EQUAL 
Act of 2018.
    If you wish further details on this estimate, we will be 
pleased to provide them. The CBO staff contacts are Sarah Puro 
and Stephen Rabent.
            Sincerely,
                                                Keith Hall,
                                                          Director.
    Enclosure.

H.R. 4861--EQUAL Act of 2018

    H.R. 4861 would nullify guidance issued in 2013 by three 
financial regulators--the Office of the Comptroller of the 
Currency (OCC), the Federal Deposit Insurance Corporation 
(FDIC), and the Federal Reserve--about certain short-term 
loans, known as deposit advance products, that banks offer to 
their customers. The bill also would require the Consumer 
Financial Protection Bureau (CFPB) to alter some current 
regulations.
    CBO estimates that those financial regulators and the CFPB 
would need a total of three to five employees for about a year, 
with an average annual compensation of $250,000 each, to 
complete the rulemaking required by the bill regarding deposit 
advance products.
    CBO expects that enacting the bill would not change the 
risk that a federally insured financial institution would fail 
because we estimate that the size of the deposit advance market 
would continue to be small under H.R. 4861. In 2013, deposit 
advance products amounted to less than 0.05 percent of the 
assets held by banks, and the loss rate of about 5 percent on 
those products was similar to that for other unsecured credit. 
Also, for the roughly 900 banks regulated by the OCC, H.R. 4861 
would have no effect on their operations because the OCC has 
already rescinded the 2013 guidance on deposit advance 
products.
    CBO estimates enacting the bill would increase the deficit 
by $1 million over the 2019-2028 period; therefore, pay-as-you-
go procedures apply. That increase comprises increased direct 
spending by the FDIC and the CFPB and decreased revenues from 
the Federal Reserve.
    CBO estimates that enacting H.R. 4861 would not 
significantly increase net direct spending or on-budget 
deficits in any of the four consecutive 10-year periods 
beginning in 2029.
    H.R. 4861 would preempt state laws and regulations that 
govern bank's short-term lending when those laws conflict with 
federal regulations issued under the bill. Although the 
preemption would limit the application of state laws and 
regulations, CBO estimates that H.R. 4861 would impose no duty 
on state, local, or tribal governments that would result in 
additional spending or a loss of revenues. Consequently, the 
cost would not exceed the threshold established in the Unfunded 
Mandates Reform Act (UMRA) for intergovernmental mandates ($80 
million in 2018, adjusted annually for inflation).
    CBO expects the FDIC and OCC would increase fees or 
premiums to offset the costs of rulemaking activities required 
by the bill. Therefore, H.R. 4861 would increase the costs of 
an existing mandate on private entities required to pay those 
fees. However, CBO estimates that the incremental cost of the 
mandate would fall well below the annual threshold established 
in UMRA for private-sector mandates ($160 million in 2018, 
adjusted annually for inflation).
    The CBO staff contacts for this estimate are Sarah Puro and 
Stephen Rabent (for federal costs) and Jon Sperl (for 
mandates). The estimate was reviewed by H. Samuel Papenfuss, 
Deputy Assistant Director for Budget Analysis.

                       FEDERAL MANDATES STATEMENT

    This information is provided in accordance with section 423 
of the Unfunded Mandates Reform Act of 1995.
    The Committee has determined that the bill does not contain 
Federal mandates on the private sector. The Committee has 
determined that the bill does not impose a Federal 
intergovernmental mandate on State, local, or tribal 
governments.

                      ADVISORY COMMITTEE STATEMENT

    No advisory committees within the meaning of section 5(b) 
of the Federal Advisory Committee Act were created by this 
legislation.

                  APPLICABILITY TO LEGISLATIVE BRANCH

    The Committee finds that the legislation does not relate to 
the terms and conditions of employment or access to public 
services or accommodations within the meaning of the section 
102(b)(3) of the Congressional Accountability Act.

                         EARMARK IDENTIFICATION

    With respect to clause 9 of rule XXI of the Rules of the 
House of Representatives, the Committee has carefully reviewed 
the provisions of the bill and states that the provisions of 
the bill do not contain any congressional earmarks, limited tax 
benefits, or limited tariff benefits within the meaning of the 
rule.

                    DUPLICATION OF FEDERAL PROGRAMS

    In compliance with clause 3(c)(5) of rule XIII of the Rules 
of the House of Representatives, the Committee states that no 
provision of the bill establishes or reauthorizes: (1) a 
program of the Federal Government known to be duplicative of 
another Federal program; (2) a program included in any report 
from the Government Accountability Office to Congress pursuant 
to section 21 of Public Law 111-139; or (3) a program related 
to a program identified in the most recent Catalog of Federal 
Domestic Assistance, published pursuant to the Federal Program 
Information Act (Pub. L. No. 95-220, as amended by Pub. L. No. 
98-169).

                   DISCLOSURE OF DIRECTED RULEMAKING

    Pursuant to section 3(i) of H. Res. 5, (115th Congress), 
the following statement is made concerning directed rule 
makings: The Committee estimates that the bill requires no 
directed rule makings within the meaning of such section.

             SECTION-BY-SECTION ANALYSIS OF THE LEGISLATION

Section 1. Short title

    This section cites H.R. 4861 as the ``Ensuring Quality 
Unbiased Access to Loans Act of 2018''.

Section 2. Nullification of, and requirements for, guidance on deposit 
        advance products

    This section nullifies the final guidance from the Federal 
Deposit Insurance Corporation titled ``Guidance on Supervisory 
Concerns 10 and Expectations Regarding Deposit Advance 
Products'' 11 (78 Fed. Reg. 70552; November 26, 2013).

Section 3. Short-term, small dollar loans

    This section states that no later than 24 months after the 
date of the enactment of this Act, the Federal banking agencies 
shall each issue regulations that supersede any State law that 
sets standards for short-term small-dollar loans, and after 
providing for public notice and comment, to establish standards 
for short-term, small-dollar loans or lines of credit made 
available by insured depository institutions.

Section 4. Exemption from payday rule

    This section states that the BCFP's final ``Payday, Vehicle 
Title, and Certain High-Cost Installment Loans'' (published at 
82 Fed. Reg. 54472; November 17, 2017) shall not apply to a 
loan made by an insured depository institution on or after the 
date that the appropriate Federal banking agencies issues such 
regulation.

         CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

    In compliance with clause 3(e) of rule XIII of the Rules of 
the House of Representatives, changes in existing law made by 
the bill, as reported, are shown as follows: H.R. 4861 does not 
repeal or amend any section of a statute. Therefore, the Office 
of Legislative Counsel did not prepare the report contemplated 
by Clause 3(e)(1)(B) of rule XIII of the House of 
Representatives.

                             MINORITY VIEWS

    H.R. 4861 would allow banks to offer payday loans, a 
practice which has essentially been banned by banking 
regulators for 5 years. The bill would overturn five years of 
sound guidance from regulators and allow Federally-insured 
banks to offer exploitative deposit advance products, which are 
essentially payday loans made by banks. The bill would also 
direct the Federal banking agencies to conduct rulemaking and 
establish standards for these kinds of bank-issued payday loans 
without the participation of the Consumer Financial Protection 
Bureau (``Consumer Bureau''). The bill would also exempt payday 
loans made by insured depository institutions or credit unions 
from the Consumer Bureau's 2017 ``Payday, Vehicle Title, and 
Certain High-Cost Installment Loans'' final rule (``payday 
rule''). Finally, the bill preempts State-level consumer 
protection laws.
    Payday loans are notorious for trapping borrowers in a 
cycle of debt. In 2014, the Consumer Bureau found in a study 
that the payday lender business model often relies on borrowers 
needing to refinance existing loans, and the average payday 
loan customer takes out 10 loans per year and spends 11 months 
in payday loan debt.\1\ Eighty percent of all payday loans are 
the result of ``rollover'' or re-borrowing, which is the 
practice of taking out a new payday loan before (or soon after) 
the old one is paid back.\2\ In other words, the borrower could 
not afford the loan in the first place. According to a 2012 
study from The Pew Charitable Trusts, payday loan borrowers 
disproportionately come from low-income households and those 
headed by minorities and single women.\3\ This is no 
coincidence, as a study released by the Center for Responsible 
lending that same year shows payday loan companies actively 
target minorities by placing branches in African-American and 
Latino communities.\4\
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    \1\https://files.consumerfinance.goy/f/201403_cfpb_report_payday-
lending.pdf
    \2\https://files.consumerfinance.goy/f/201403_cfpb_report_payday-
lending.pdf
    \3\http://www.pewtrusts.org//media/legacy/uploadedfiles/pcs_assets/
2012/pewpaydaylendingreportpdf.pdf
    \4\http://www.responsiblelending.org/sites/default/files/nodes/
files/research-publication/predatory-profiling.pdf
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    The idea that insured depository institutions would, if 
presented with the opportunity, only offer affordable payday 
loan products is misguided, and has been disproven by history. 
Prior to 2013, some banks--such as Wells Fargo, Regions, Fifth 
Third, US Bank, Bank of Oklahoma, and Guaranty Bank--were 
making 300%-plus interest rate loans, which they called 
``deposit advance'' products, but that functioned identically 
to non-bank payday loans.\5\
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    \5\https://www.washingtonpost.com/business/economy/wells-fargo-us-
bank-to-end-payday-loans-citing-tougher-regulation/2014/01/17/b65f0512-
7f82-11e3-93c1-0e888170b723_story.html?utm_term=.e2aa419e0185
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    Deposit advance products are small-dollar, short-term loans 
that banks make available to customers with direct deposit. The 
customer is allowed to take out a loan, which is to be repaid 
from the proceeds of the next direct deposit. These loans 
typically have high fees, are repaid in a lump sum in advance 
of the customer's other bills, and often do not utilize prudent 
banking practices to determine the customer's ability to repay 
the loan and meet other necessary financial obligations.\6\ 
These bank-issued deposit advance products often operated as 
debt traps, with borrowers refinancing their payday loans 
multiple times and accumulating thousands of dollars in 
associated fees.\7\
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    \6\https://www.occ.goy/news-issuances/news-releases/2013/nr-ia-
2013-182a.pdf
    \7\Robert Benincasa, Banks Come Under Fire for Filling in the 
Payday Loan Gap, NPR (Dec. 5, 2013), https://www.npr.org/2013/12/05/
247182721/banks-fill-in-the-payday-loan-gap.
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    For example, in a 2013 hearing on payday loans and older 
Americans with the Senate Special Committee on Aging,\8\ a 69-
year-old California woman testified about how she ended up 
paying $3,000 in fees on a $500 deposit advance loan she took 
out with Wells Fargo.\9\ In 2013, in response to Congressional 
outcry against high-cost, bank-issued deposit advance loans, 
the Federal Deposit Insurance Corporation (``FDIC'')\10\ issued 
guidance aimed at curbing the harms of the more predatory 
deposit advance products being offered by banks. At the same 
time, the Federal Reserve and Office of the Comptroller of the 
Currency (``OCC'')\11\ issued similar supervisory statements to 
the same effect.\12\ H.R. 4861 would repeal this guidance.
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    \8\https://www.aging.senate.gov/press-releases/hearing-to-examine-
the-impact-of-payday-lending-on-seniors
    \9\Chris Morran, Wells Fargo Customer Explains How $500 Loan 
Resulted In $3,000 Fees, Consumerist (July 26, 2013), https://
consumerist.com/2013/07/26/wells-fargo-customer-explains-how-500-loan-
resulted-in-3000-in-fees/.
    \10\https://www.fdic.gov/news/news/press/2013/pr13105a.pdf
    \11\https://www.occ.gov/news-issuances/news-releases/2013/nr-ia-
2013-182a.pdf
    \12\https://www.federalreserve.gov/supervisionreg/caletters/
caltr1307.htm
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    H.R. 4861 would also direct the Federal banking agencies to 
coordinate and issue regulations, within 24 months, 
establishing standards for the offering of short-term, small-
dollar loans or lines of credit by insured depository 
institutions. This would create a two-year gap where no 
regulatory guidance is in place for payday loans offered by 
certain banks. Furthermore, the National Credit Union 
Administration (``NCUA'') and the Consumer Bureau are 
inexplicably left out of the rulemaking process, even though 
the bill would exempt loans offered by credit unions from the 
Consumer Bureau's final payday rule.
    The Consumer Bureau's payday rule provides important, 
common-sense protections for payday loans, auto title loans, 
deposit advance products, and other longer term loans with 
balloon payments. Under the rule, lenders must conduct ability-
to-repay analyses to determine whether a borrower can actually 
repay the full amount of the loan without re-borrowing. The 
rule also imposes requirements concerning lender withdrawal 
practices, disclosures, and recordkeeping.
    Prior to the creation of the Consumer Bureau in the Dodd-
Frank Wall Street Reform and Consumer Protection Act, Federal 
banking agencies were tasked with the dual, and frequently 
incompatible, responsibilities of supervising financial 
institutions for safety and soundness as well as for compliance 
with consumer protection laws. This inherent regulatory 
conflict often resulted in financial institutions' attention to 
consumer protections taking a subordinate role to safety and 
soundness concerns. As a result, Congress designed the Consumer 
Bureau with a primary mission to protect consumers. H.R. 4861 
inappropriately weakens the Consumer Bureau's payday rule and 
places primary oversight for payday loans with the Federal 
banking agencies, in contravention of Congress's clear intent 
to vest primary consumer protection and oversight 
responsibilities with the Consumer Bureau.
    H.R. 4861's preemption of State laws on payday loans would 
cause states to lose their current authority over abusive 
products by the banks that they charter and regulate. Fifteen 
States and the District of Columbia have enacted double-digit 
interest rate caps, which are effectively payday loan bans,\13\ 
and since 2005, no State has authorized high-cost payday loans. 
According to the Center for Responsible Lending, State-level 
payday loan bans save consumers more than $2.2 billion annually 
in fees that would otherwise be paid to payday lenders.\14\ It 
would be irresponsible for Congress to subvert these States by 
repealing their authority to enact and enforce strong consumer 
protections.
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    \13\http://www.responsiblelending.org/sites/default/files/nodes/
files/research-publication/crl-shark-free-waters-aug2016.pdf
    \14\http://www.responsiblelending.org/sites/default/files/nodes/
files/research-publication/crl-shark-free-waters-aug2016.pdf
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    While Congress must continue to seek solutions that address 
access to credit, this bill is not the answer. For these 
reasons, we oppose H.R. 4861.

                                   Maxine Waters.
                                   Michael E. Capuano.
                                   Al Green.
                                   Carolyn B. Maloney.
                                   Nydia M. Velazquez.
                                   Denny Heck.

                                  [all]