Americans for Financial Reform Education Fund, Better Markets, California Reinvestment Coalition, Center for Responsible Lending, Community Service Society of New York, Consumer Reports, Empire Justice Center, Main Street Alliance, National Association of Consumer Advocates, National Consumer Law Center (on behalf of its low income clients), New Economy Project, Public Citizen, Small Business Majority, U.S. PIRG, and Woodstock Institute submit these comments on the Consumer Financial Protection Bureau’s (CFPB) intent to make a preemption determination concerning whether the Truth in Lending Act (TILA) preempts a New York State commercial financing law with respect to certain disclosure provisions. The groups agree that TILA does not preempt the New York law or similar laws. Even though the specific question before the CFPB affects only business lending, a ruling that the New York law was preempted would set a very dangerous precedent for consumers. Such a broad scope of preemption would invite challenges to thousands of state consumer protection laws, making them much more difficult for consumers and state enforcement authorities to enforce.
See all resources related to: Consumer Protection Regulation