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	<author_name>Americans for Financial Reform</author_name>
	<author_url>https://actionnetwork.org/groups/afr-advocacy-fund-c4</author_url>
	<title>Block Predatory 100% APR Banks Nationwide</title>
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	<description>Predatory lenders Enova International and Opportunity Financial, known as OppFi, are trying to acquire national banks. They are attempting to gain the power to override state interest-rate protections and spread triple-digit loans across the country. Enova, which owns CashNetUSA, NetCredit, and OnDeck, has applied to acquire Grasshopper Bank. OppFi has announced an agreement to acquire BNC Bank. If these deals are approved, they could create the first national banks whose core business models center on predatory loans carrying rates of 100% to 160% APR or higher. The strategy is clear. National banks can generally export the interest-rate rules of their home states when lending nationwide. Enova and OppFi want to use that privilege to evade protections established by other states. A $2,000 loan at 100% APR is prohibited in 45 states, yet these acquisitions could allow the companies to impose those rates on people living in those states anyway. Their records show why the Federal Reserve must intervene. Enova’s consumer loans have experienced charge-off rates exceeding 50%. OppFi offers loans with APRs reaching 195%, has disclosed a 51.4% net charge-off rate, and relies heavily on repeated refinancing that keeps borrowers paying exorbitant interest for extended periods. These companies should not be rewarded for unaffordable lending with the extraordinary privileges of national bank ownership. A federal banking charter must not become a license to nullify state consumer protections, target financially vulnerable communities, or normalize triple-digit interest rates throughout the banking system. More than 60 consumer, civil rights, labor, small business, legal services, and community organizations have demanded public hearings and a full vote of the Federal Reserve Board. These decisions must not be quietly delegated or approved behind closed doors. The communities placed at risk deserve to be heard. Add your name now &amp;gt;&amp;gt; Full Petition Text: TO: The Federal Reserve Board RE: Block Enova and OppFi From Using National Bank Charters to Evade State Interest-Rate Laws I urge the Federal Reserve to deny Enova International’s application to acquire Grasshopper Bank and to reject Opportunity Financial’s proposed acquisition of BNC Bank when it comes before the Board. These companies are seeking the privileges of national bank ownership in order to override state interest-rate protections and expand predatory triple-digit lending nationwide. If approved, these transactions could create the first national banks whose core business models focus on loans carrying interest rates of 100% to 160% APR or higher. A $2,000 loan at 100% APR is prohibited in 45 states. Yet national bank ownership could allow Enova and OppFi to export the rules of a bank’s home state and evade the protections adopted by voters and lawmakers elsewhere. The Federal Reserve should not allow a federal banking charter to become a tool for nullifying state consumer-protection laws. The companies’ lending records make the danger unmistakable. Enova’s consumer-loan charge-offs have exceeded 50%. OppFi offers loans with APRs reaching 195%, has disclosed a 51% net charge-off rate, and derives a substantial share of its income from refinancing borrowers into continuing high-cost debt. These figures demonstrate severe unaffordability, not responsible underwriting. Enova also has a documented history of consumer protection violations. The CFPB labeled the company a repeat offender in 2023 after finding continued illegal conduct following a previous enforcement order. Advocates have also identified a disproportionate concentration of consumer complaints against Enova in predominantly Black and Latino communities. That history should weigh heavily against granting the company control of a national bank. National bank charters are public privileges. They must not be used as escape routes from state law or as vehicles for spreading unaffordable debt traps. Please deny Enova’s application, block OppFi’s proposed acquisition, and prevent the creation of national banks dedicated to predatory 100% APR lending. The Undersigned</description>
	<url>https://actionnetwork.org/forms/block-predatory-100-apr-banks-nationwide</url>
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