Press Release: Consumers’ Research Analysis Finds Form Letter Comment Submissions to the CFPB on Payday Loan Rule Used Equally by Proponents & Opponents


CONTACT: Steve Burke, (703) 683-5004, ext. 1108 or

Group Refutes Insinuation Payday Lending Industry is ‘Tainting’ Rulemaking Process

Washington, D.C.—May 16, 2019: In response to published reports this week that supporters of the Consumer Financial Protection Bureau’s (CFPB) reconsideration of the payday loan rule had submitted thousands of “duplicated comments,” Consumers’ Research’s analysis of comments found that characterization doesn’t accurately tell the full story. In fact, a “broader analysis suggests that form letters were used at roughly equal rates by both proponents and opponents of this rule,” says the group in its comment submission to the Bureau on this rule.  

From April 17, 2019 to May 14, 2019, Consumers’ Research analyzed over 1,000 comments submitted to the CFPB regarding the Bureau’s 2019 Proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule. The comments were divided into three separate and random statistical samples. In their most recent analysis of 379 comments (out of a sample size of 25,995 comments), the organization found that 191 or 50% of them were either confirmed or highly suspected of being form letters. Of this group, 53% were positive to the CFPB’s proposed changes to the rule, while 47% were negative or otherwise opposed to the proposed changes.

Beau Brunson, Senior Policy Advisor of Consumers’ Research said:

“While generated form letters are a fact of life when it comes to the rulemaking comment process, it is highly irresponsible for others to suggest that only one side is engaging in the practice, either because of a failure to identify or report all the facts.”

For more on the analysis, please visit (pages 6-9) of Consumers’ Research’s comment to the CFPB on the rule:

Brunson continued:

“We are encouraged that the CFPB, under Kathy Kraninger’s direction, has indicated that it is going to take a more ‘transparent and deliberative’ approach to rulemaking and in that spirit, we believe greater emphasis should be placed on more thoughtful, organic comments.”

About Consumers’ Research:

Consumers’ Research, founded in 1929, is the nation’s oldest consumer organization that seeks to increase the knowledge and understanding of issues, policies, products, and services of concern to consumers. For more information, visit:
and follow Consumers’ Research on Twitter at @ConsumersFirst.

About the Analysis of Submitted Regulatory Comments:
Consumers’ Research calculated the necessary sample size, given a 95 percent confidence level and 5 percent margin of error, using a sample size calculator provided by SurveyMonkey.   

+ posts


Share on facebook
Share on twitter
Share on linkedin
Share on email

Subscribe to get the latest consumer news

More consumer News