May 15, 2018

Ms. Kathleen Kraninger, Director
Consumer Financial Protection Bureau
1700 G Street NW
Washington, DC 20552

Re: Comments on Proposal to Rescind Ability-to-Repay Requirements Governing Payday, Vehicle Title, and Certain High-Cost Installment Loans, Docket No. CFPB-2019-0006; RIN 3170-AA80

Dear Director Kraninger:

We stand together to oppose the agency’s proposal to stop the implementation of the payday and car title lending rule. Ohioans have been exploited by payday lending and we insist that the 2017 proposed rule to regulate the industry take effect without further delay.

Ohio has the most expensive and abusive payday loans in the country with borrowers paying over $500 million a year in fees to payday lenders. Borrowers trapped in a cycle of debt are charged excessive overdraft fees, have their bank accounts closed, face bankruptcy, and get their cars repossessed.

In 2008, Ohio passed the strongest payday lending regulation legislation in the country. Voters approved the legislation by a vote of 2-to-1 in a referendum the industry placed on the ballot. Unfortunately, lenders found loopholes in the legislation and now charge the nation’s highest average interest rates of 677% annual percentage rate.

Although Ohio passed new payday loan legislation last year, the CFPB rule is still necessary to truly protect consumers. The state law is focused on a restricting excessive interest rates and fees. The CFPB rule will require lenders to assess a borrower’s individual financial circumstances to ensure they can repay the loan without financial hardship. The “ability to repay provision” is a common sense approach will keep many Ohioans from incurring debt they cannot afford. The state law and the CFPB rule are complimentary measures; together they provide critical safeguards to shut down Ohio’s debt trap once and for all.

Congress created the Consumer Financial Protection Bureau to protect Americans from deceptive and abusive business practices of the financial services industry. Current efforts to impede implementation of the payday rule run contrary to its mission. We ask that you restore to its true purpose and implement this rule without delay.

Sincerely,