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.
OLA Comment: Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B) Docket No. CFPB 2021-0015