Comment Letter

Comment Letter: Small-Dollar Lending

The Center for Financial Services Innovation responds to the FDIC’s Request for Information on Small-Dollar Lending based on our research into the consumer behaviors, products, and providers that comprise the market for small-dollar credit.

Comment Letter on Credit Scoring

The Center for Financial Services Innovation (CFSI) shares its perspective on how the Federal Housing Finance Agency (FHFA) can ensure that the Enterprises’ standards and processes can benefit consumers' financial health.

The Financial Health Network Comment Letter on Proposed Amendments to Rules Concerning Prepaid Accounts

The Financial Health Network submitted this letter in response to the request for comment on the proposed Amendments to Rules Concerning Prepaid Accounts, issued by the Consumer Financial Protection Bureau (CFPB, the Bureau) and published on June 29, 2017. Like the CFPB, we recognize the important role that prepaid products and services can play in the financial health of U.S. consumers and we are committed to promoting high-quality financial products. We believe that financial services can be a force for good in people’s lives and that meeting consumers’ needs responsibly is ultimately good for both the consumer and the provider.

The Financial Health Network Comment Letter on Information Regarding Consumer Credit Card Market

The Financial Health Network submitted this letter in response to the CFPB’s request for information on consumer credit card markets on March 10, 2017. Like the CFPB, the Financial Health Network recognizes the important role that access to high-quality financial products plays in helping consumers improve and maintain their financial health. We believe that finance can be a force for good in people’s lives and that meeting consumers’ needs responsibly is ultimately good for both the consumer and the provider.

The Financial Health Network Comment Letter to the CFPB’s Request for Information Regarding Use of Alternative Data and Modeling Techniques in the Credit Process

The Financial Health Network submitted its response to the CFPB’s request for information regarding use of alternative data and modeling techniques in the credit process on February 16, 2017. In the letter, the Financial Health Network acknowledges that the use of alternative data in the credit process poses both risks and benefits to consumers. The letter also states the Financial Health Network’s belief that consumers will be better able to achieve financial health if they have access to innovative credit products that are safe, affordable, and of high quality, enabling them to manage their day-to-day finances, weather financial shocks, and pursue longterm opportunities.

The Financial Health Network Comment Letter to the CFPB Regarding Consumer Access to Financial Records

The Financial Health Network submitted its response to the CFPB’s Request for Information Regarding Consumer Access to Financial Records. In the letter, the Financial Health Network describes how companies should design data-sharing partnerships to support consumer choice and innovation. The letter also urges the CFPB to support the industry’s efforts to develop solutions by affirming consumers’ right to access their financial data through principles-based guidance.