AFSA's State Government Affairs team recently submitted a comment letter to the Rhode Island Senate Committee on Commerce about Senate Bill 17, aimed at addressing "junk fees" and deceptive pricing practices. The association expressed concern about the bill's broad language, suggesting it might unintentionally impact financial institutions already governed by federal laws such as the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA).
These federal laws require clear disclosures of terms, fees, and costs. AFSA noted that without exemptions or safe harbors for entities complying with these statutes, Senate Bill 17 could lead to conflicting obligations and legal uncertainties for regulated lenders.
The association recommended that the bill be amended to state that compliance with TILA or RESPA would be considered compliance with S 17. AFSA pointed out that other states, including California, have adopted similar measures to ensure consumers receive strong protections without adding duplicative requirements on lenders.
The full comment letter, along with other State Government Affairs letters, is available on the direct advocacy section of AFSA's website.