August 2, 2016
Good Morning,
Why is everybody asking me to reply to the CFPB proposed short
term lending rules? The short answer: It may keep you in
business!
The
process of promulgating new federal rules
is a structured process. Posting the rule and receiving
and reviewing responses is part of that process. In
reality, every reply must be reviewed and categorized. How
does that happen? Easy. Each reply must be read.
Think about it. If the industry sends in 500,000 replies
how long do you think the review process will take? We
understand somewhere in the range of 200,000 replies have been
sent so far. The deadline is October 7. It is not
out of the question for there to be 1,000,000 replies.
WOW! How would you like the job of going through each
and every one of those replies? How long do you think that
would take?
Don't take our word for it, see
this article
from
USA Today from last week. It is regarding experience with
other rules and the impact of replies. The same may well
happen with this rule for us. Let's hope so.
Here are a few ideas for responding. Choose one or more
for ideas on how you can reply:
1.
See
this letter by one of our friends in the industry to solicit
customers and others. It's short and to the point.
2.
You should have an attorney who is familiar with this issue
draft a formal reply from your company to the CFPB. We
understand that if you are a FISCA member they will do this for
you at no cost. Having the right information in your reply
can make a big difference in the event of future legal
challenges.
3.
Go to the special FISCA platform at
www.fiscaaction.com/take-action. You should find
everything you need to comply and reply.
4.
Go to the special CFSA platform at
http://creditstrengthenscommunities.com. Like the link
above, this one has all you might need.
5.
You can go directly to
this link and post your comments. By the way, while on
the site you can browse to see how others have responded.
Finally, we know you you have plenty to do. One more
little project will not hurt :-). This one could very well make
a BIG difference. Please do your part if you are
planning on staying in this business (actually, do it even if
you are not planning on staying).
Thank you!
- Max
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