The National Consumer Law Center (“NCLC”) submitted the following comments on behalf of its low-income clients and Americans for Financial Reform, Consumer Action, Consumer Federation of America, NAACP, National Association of Consumer Advocates, U.S. PIRG and Woodstock Institute.
We appreciate the comprehensive nature of the CFPB’s proposed assessment plan of the Remittance Rules. However, we would like to encourage the CFPB to focus its evaluation on the many exceptions to the rules and the effect on consumers of these exceptions.