The Financial Health Network is submitting this letter in response to the request for comments on the “Proposed Guidance for Third-Party Lending” issued by the Federal Deposit Insurance Corporation (FDIC) and published on July 29, 2016.

Over the last two decades, the emergence of new intermediaries that aggregate data from numerous sources has enabled financial services providers of all kinds to provide consumers with a more complete view of their financial lives. – See more at: http://cfsinnovation.org/research/consumer-data-sharing-principles-a-brief-on-the-framework-for-industry-wide-collaboration/#sthash.oYX1cTQi.dpuf

Over the last two decades, the emergence of new intermediaries that aggregate data from numerous sources has enabled financial services providers of all kinds to provide consumers with a more complete view of their financial lives.

The Financial Health Network is submitting this letter in response to the request for comments on “Payday, Vehicle Title, and Certain High-Cost Installment Loans,” issued by the Consumer Financial Protection Bureau (CFPB) and published on July 22, 2016.

The Center for Financial Services Innovation (CFSI) offers consulting services that guide organizations through each stage of offering new solutions, from development to ongoing measurement.

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.

This paper takes a closer look at the eight indicators we’ve identified and ways that providers can help.

The Financial Health Network has developed eight indicators to measure financial health. We believe that these indicators establish a framework for shifting the financial services industry towards a focus on financial health, a focus on improving consumers’ lives.

We can educate consumers and provide access to financial products and services. But how do we help consumers use their knowledge and tools to improve their financial behavior and become financially healthy?

Despite strong member satisfaction and negative consumer sentiment towards banks, credit unions’ market share of key profit drivers like mortgages and credit cards is in the single digits.

Can a workplace financial counseling program leverage mobile tools to boost the financial health of low-and-moderate income employees?

Discover eight learnings that the Center for Financial Services Innovation (CFSI) has gathered while helping more than 100 financial institutions engage more meaningfully with their customers.

USAID and the U.S. Treasury Department hosted a FinX, an in-the-field opportunity that puts participants in consumers’ shoes and has them tackle the challenges they face head-on.

MyBudgetCoach (MyBC), operated and distributed by Solutions for Progress (SfP), is an online platform designed to complement and enhance existing financial coaching programs.

Taking a deeper look at data collected for our Consumer Financial Health Study released in March 2015, this Network-exclusive report highlights the financial behaviors, challenges, product usage patterns and demographics of small-dollar credit users.

This report reveals that financially underserved American consumers spent $138 billion in fees and interest revenue in 2014, generated from a volume of $1.6 trillion in financial activity.

LIFT-UP (Local Interventions for Financial Empowerment through Utility Payments) is a multi-city initiative overseen by the National League of Cities’ (NLC) Institute for Youth, Education, and Families designed to provide financial counseling to delinquent utility customers

In 2010, Mission Economic Development Agency (MEDA) launched its Volunteer Income Tax Assistance (VITA) Credit Builder program with the primary goal to establish or improve credit for low-income Latino immigrants and help them responsibly manage credit over the long term.

Millions of Americans are raising children in households with poor family financial health and limited financial resources.

This infographic illustrates the types and uses of Small-Dollar Credit products.

Millions of Americans lack access to high-quality, affordable credit. While innovating in the small-dollar credit industry poses challenges, the opportunity to serve borrowers in need of high-quality, small-dollar loans is significant.

Mission Asset Fund’s (MAF) Lending Circles provides a zero-interest loan to help consumers build credit and access an affordable small-dollar loan.

Piggymojo built an online and mobile tool that uses goal visualization, social sharing and mobile technology to help savers turn impulse buys into “impulse saves.”

Over 29 million Americans comprise the “at risk” segment – most likely of all the segments to live paycheck to paycheck and run out of money before the end of the month.

A whopping sixteen percent of the country is unengaged with their financial situation. This segment earns its name from these consumers’ lack of awareness about their financial lives and their low level of engagement with traditional financial services.

More than half of Americans in the tenuous segment live paycheck to paycheck (53%) and struggle to keep up with bills and credit payments.

Strivers are generally able to make ends meet, but many of them are not satisfied with their current financial situation and are working to better their financial circumstances.

The Financial Health Network recognizes that access to high-quality financial products are crucial to help consumers improve and maintain their financial health.

This research takes a look at an important component of consumer financial health: the credit score. The Financial Health Network appended two objective measures of credit-worthiness to the Consumer Financial Health Study.

This research explores the state of financial health in America in a groundbreaking examination of consumer behaviors, attitudes, and preferences.

The Survey Instrument is the full questionnaire that was fielded for the Consumer Financial Health Study, Understanding and Improving Consumer Financial Health in America.

This paper examines four key trends and explores how real-life companies are leveraging Big Data in financial services.

The Compass Guide to Payroll Cards defines industry-wide best practices for the design and delivery of payroll cards.

The Financial Health Network believes that access to high-quality financial services is necessary for consumers’ financial health.