HOPE Submits Opinions Opposing OCC Real Lender
Please find below the commentary regarding the Hope Enterprise Corporation / Hope Credit Union/Hope Policy Institute (HOPE) as a result to your OCC Notice of Proposed Rulemaking, National Banks and Federal Savings Associations as Lenders, HOPE is just a credit union, community development institution that is financial policy institute providing you with affordable monetary solutions; leverages personal, public and philanthropic resources; and engages in policy analysis to meet its mission of strengthening communities, building assets, and increasing everyday lives in economically distressed areas throughout Alabama, Arkansas, Louisiana, Mississippi and Tennessee. During the last 25 years, HOPE has produced over $2.5 billion in financing which has had benefited significantly more than 1.5 million people.
Provided the experiences of our users, described herein, we have been worried that the OCC proposition will rather add to than alleviate, the burdens of high expense financing within our area. In most five Deep South states, high price loan providers, such as for example payday and vehicle name loan providers, are generally saturating our communities. As an example, in 2017 in Tennessee, there have been over 1,200 loan that is payday, significantly more than McDonald’s and Walmart places combined. 1 when it comes to costs drained by payday and automobile name loan providers, Mississippi, Alabama, Louisiana, and Tennessee come in the very best ten states, and cost that is high strain a lot more than $1.6 billion each year from low earnings borrowers during these four states. 2