The National Consumer Law Center and Consumer Action respectfully submit the following comments on behalf of its low-income clients. We welcome the opportunity to comment on the Bureau’s proposal to amend the ability-to-pay requirement of Regulation Z, 12 C.F.R. § 1026.51(a), which was promulgated pursuant to the Credit Card Accountability, Responsibility and Disclosures (CARD) Act of 2009, 15 U.S.C. § 1665e.