Family Finances

Statement on CFPB Proposed Rule to Rescind ATR Requirements

May 17, 2019  • Ida Rademacher & Financial Security Program

On May 15, the Consumer Financial Protection Bureau’s (CFPB) comment period on the Proposed Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans (RIN 3170-AA80) closed. If passed, this rule will rescind mandatory underwriting provisions set by the CFPB in November of 2017 governing these small dollar high-cost loans. The Aspen Institute Financial Security Program (Aspen FSP) submitted a comment letter in opposition to the proposed rule to the CFPB.

Aspen FSP’s Executive Director Ida Rademacher released the following statement in response to the proposed rule:

“The Aspen Institute Financial Security Program has spent the last two years studying consumer debt in America, and we deeply understand how harmful this regulatory change would be for so many low- and moderate-income Americans. We rarely comment on policy this explicitly, but we cannot stand to the side as the CFPB takes this step backwards in consumer financial protections. Put frankly: years of evidence shows this proposed rule is a poor decision. There’s a reason these rules were put in place – they reduce consumers’ exposure to harmful loan terms and features. We urge the Bureau to begin enforcing the existing regulations on small-dollar lending as soon as possible. Aspen FSP has identified ability-to-repay underwriting requirements for small-dollar loans as an important government-led solution to reducing consumers’ exposure to harmful loan terms and features. Regardless of party lines, it’s important that these types of common-sense regulations — ones which, according to all evidence from a broad range of sources, help consumers get financially secure — stay in place.”

For more information on Aspen FSP’s Consumer Debt work we encourage you to visit

Family Finances
Solving the Consumer Debt Crisis: An Action Guide for Local Government
February 19, 2019 • Financial Security Program