The American Financial Services Association (AFSA) has submitted comments on recent rules set by the Community Development Financial Institutions (CDFI) Fund. The CDFI Fund offers financial support to eligible institutions, with recipients required to report significant events that could affect their eligibility for funding.
In its letter, AFSA expressed concerns about certain requirements imposed by the CDFI Fund. Specifically, AFSA pointed out that eligibility now includes a 36% Military Annual Percentage Rate (APR) cap on loans and a list of loan characteristics. According to AFSA, these restrictions are not appropriate for a federal agency to enforce and could reduce access to credit in areas where state laws permit such loans.
"Our letter urges CDFI to stop imposing these limits, as these limits are improper for a federal agency to impose and limit the availability of credit in places where state laws allow such loans to exist," AFSA stated.