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FDIC RFI on Small Dollar Lending
On January 22, 2019, OLA provided comments to the FDIC in response to an Agency RFI on increasing small dollar lending by FDIC regulated institutions. The focus of OLA comments covered the following topics: Bank fintech partnerships and the need to address current legal impediments Impact that a 36% interest rate cap will have Need […]
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OLA Provides Comments on Enhanced BCFP Trial Disclosure Program
Recently, the newly created Office of Innovation at the Bureau of Consumer Financial Protection (BCFP) announced changes to its “Trial Disclosure Program”. Under Dodd-Frank, the BCFP was given the authority to allow companies the ability to conduct trial disclosure programs and to provide a safe harbor (or waiver) from the corresponding applicable regulatory requirements. The […]
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OLA files comment in response to Evidentiary RFI dealing with improving the CID process
OLA Files Comment in Response to Evidentiary RFI Dealing with Improving the CID Process At the end of 2017, Acting Director Mulvaney of the Consumer Financial Protection Bureau (CFPB) announced that he would be undertaking a new initiative to ensure that the Bureau’s operations were fulfilling its proper and appropriate functions to best protect consumers. […]
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OLA Sends Letter to CFPB Acting Director Mulvaney
Today, Online Lenders Alliance President and CEO, Lisa McGreevy, sent a letter to CFPB Acting Director Mulvaney, thanking him for his leadership during this time of transition, and sharing our Fintech Bill of Rights for consideration as he examines reform to the CFPB.
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OLA Responds to CFPB RFI on Use of Alternative Data
On May 19th, OLA submitted a comment letter to the CFPB in response to an RFI issued by the agency in February. OLA members have been leaders in the alternative data field, building new and innovative models to assist in broadening the availability of capital to consumers. The letter focused on a broad range of topics […]
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OLA Letter to Google regarding AdWords Financial Services Policy
Lisa McGreevy, President and CEO of the Online Lenders Alliance (OLA), sent a letter to Google’s Senior VP & General Counsel in regards to the Ad Words Financial Services Policy update in July 2016. OLA and our Members believe that the terms of the policy cause harm by preventing consumers who are legitimately searching […]
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OLA Files Comments with CFPB on Consumer Data Access
In response to a Request for Information (RFI) by the Consumer Financial Protection Bureau (CFPB) regarding Consumer Access to Financial Records, OLA filed Comments with the CFPB regarding the industry’s views on consumer data and their ability to share that data with third-party organizations. Dodd-Frank Wall Street Reform and Consumer Protection Act Section 1033 outlines […]
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OLA Files Comment Letter on Small Dollar Lending Rule to CFPB
In June 2016, the Consumer Financial Protection Bureau released its proposed rule regulating the market for payday, vehicle title and similar loans. OLA submitted a letter for the record on October 7, 2016. You can view it by clicking here.
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OLA Comment Letter on CA PRO 04/08 – CDDTL Report Regulations
June 23, 2015 Commissioner Jan Lynn Owen California Department of Business Oversight 1515 K St., Suite 200 Sacramento, CA 95814 RE: PRO 04/08 – CDDTL Report Regulations Dear Commissioner Owen: The Online Lenders Alliance (OLA) is pleased to submit this response to the California Department of Business Oversight’s (the Department) request for comment related […]
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OLA Letter to Director Cordray on CFPB Rule
Read: 02-20-2015 Letter to Director Cordray
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Proposed Guidance on Deposit Advance Products
The Online Lenders Alliance (“OLA”) submitted this comment letter in response to the Proposed Guidance on Deposit Advance Products. For the reasons outlined in the letter, OLA opposes the Proposed Guidance and urges that the Proposed Guidance be withdrawn. Comment Letter to Proposed Guidance on Deposit Advance Products 5-30-2013 PDF
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U.S. Court of Appeals Decision on NLRB Appointment
The U.S. Court of Appeals for the Third Circuit issued an opinion holding that a purported “recess” appointment to the National Labor Relations Board (NLRB) was invalid and unconstitutional. This decision echoes the earlier decision of the U.S. Court of Appeals for the District of Columbia Circuit in Noel Canning v. NLRB, and holds that […]
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Policy to Encourage Trial Disclosure Programs
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. Comment on CFPB Trial Disclosure Policy 02152013
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