In a comment letter dated May 15, 2019, regarding the CFPB’s most recent Payday Lending rulemaking, CBAI highlighted the Association’s and members community banker involvement in the original, long, unnecessary and distressing Payday Lending rulemaking process which culminated in the Bureau’s 2017 Final Payday Lending Rule. The reason for our concern and effort to aggressively respond to this rulemaking was that the proposed regulations, while designed to curb the excesses of payday lenders, inappropriately included and would have harmed community banks. Despite the Bureau’s statement that it recognized the importance of community banks in small-dollar consumer lending, and that it had addressed the concerns of community banks, they should have never been included the Payday Lending rulemaking process. Additionally, the Final Payday Lending Rule fell short of what was required to encourage community bankers to begin, continue or expand small-dollar consumer lending. CBAI again urged the Bureau in to expand the use of its statutory authority to broadly exempt community banks so they may better serve their customers and communities in a fair and responsible manner. Read Comment Letter.