Brighter Futures Start with HOPE.Dear Chairman Brooks:

Brighter Futures Start with HOPE.Dear Chairman Brooks:

HOPE Submits Responses Opposing OCC Real Lender

3rd, 2020 september

2, 2020 september

Acting Comptroller for the Currency Brian Brooks 400 7th St SW Washington, DC 20219

Re: remarks on Proposal “National Banks and Federal Savings Associations as Lenders” Docket ID: OCC-2020-0026 RIN 1557-AE97

Please find underneath the feedback of this Hope Enterprise Corporation / Hope Credit Union/Hope Policy Institute (HOPE) in reaction into the OCC Notice of Proposed Rulemaking, National Banks and Federal Savings Associations as Lenders, OCC-2020-0026, RIN-1557-AE97.

HOPE is a credit union, community development institution that is financial policy institute that delivers affordable monetary solutions; leverages personal, public and philanthropic resources; and partcipates in policy analysis to satisfy its objective of strengthening communities, building assets, and enhancing life in economically troubled areas throughout Alabama, Arkansas, Louisiana, Mississippi and Tennessee. Throughout the last 25 years, HOPE has produced over $2.5 billion in funding that features benefited significantly more than 1.5 million people.

Offered the experiences of our users, described herein, we have been worried that the OCC proposition will enhance, instead than alleviate, the burdens of high-cost financing inside our area. In most five Deep South states, high-cost loan providers, such as for example payday and vehicle name loan providers, already are saturating our communities. For instance, in 2017 in Tennessee, there have been over 1,200 pay day loan storefronts, significantly more than McDonald’s and Walmart places combined. 1 when it comes to charges drained by payday and vehicle name lenders, Mississippi, Alabama, Louisiana, and Tennessee come in the very best ten states, and lenders that are high-cost a lot more than $1.6 billion each year from low-income borrowers in these four states. 2