These joint comments, filed by NCLC (on behalf of our low-income clients), the Center for Responsible Lending, and the Consumer Federation of America, support an interpretive rule proposed by the CFPB that would clarify that earned wage advance products are credit transactions as defined by the Truth in Lending Act, and that “expedite fees” and “tips” charged in connection with these transactions are finance charges. The comments also urge the CFPB to broaden and clarify the proposed rule in various ways.
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