The National Consumer Law Center, on behalf of its low-income clients, the Center for Responsible Lending, Consumer Action, the Consumer Federation of America, the National Association of Consumer Advocates, the New Economy Project, and U.S. PIRG, write to comment on the issuance of the Interagency Guidance regarding Unfair or Deceptive Credit Practices (“Guidance”) and the proposed repeal of Regulation AA (“Reg. AA”). We commend the issuance of the guidance, but urge that the Consumer Financial Protection Bureau issue an immediate interim final rule with the substantive language in Reg AA – as it has done before in regards to Regulation D (see discussion below at the end of Section I). We also urge that the Guidance be strengthened.
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