OLA submitted a comment letter responding to the CFPB ‘s Proposed Trial Disclosure Policy. Although the letter addresses the Proposed Policy and makes recommendations for improvement, the focus is on APR and how APR is an ineffective and misleading measure of the cost of a short-term loan.
Policy to Encourage Trial Disclosure Programs
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OLA California Comments on Department of Financial Protection and Innovation’s (DFPI) proposal to amend the Pilot Program for Increased Access to Responsible Small Dollar Loans (PRO 04-21).
CommunicationsSeptember 20, 2021
OLA Comment: Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B) Docket No. CFPB 2021-0015