February 4, 2022 — Letter

Accountable.US, Americans for Financial Reform Education Fund, Center for Responsible Lending, Consumer Action, Consumer Federation of America, Consumer Reports, the Leadership Conference on
Civil and Human Rights, NAACP, National Association of Consumer Advocates, National Community
Reinvestment Coalition, National Consumer Law Center (on behalf of its low-income clients), Public Citizen, U.S. PIRG, UnidosUS and the Woodstock Institute write to urge the FDIC to stop permitting its
supervised institutions to front for predatory lenders evading state interest rate limits.

FDIC-supervised banks are helping predatory lenders make loans up to 225% APR that are illegal in
almost every state.
These rent-a-bank schemes often operate under the guise of innovative “fintech”
products, even as their high-cost, high-default business model inflicts harms similar to those inflicted by
traditional payday lenders.