Larger Participants: Any non-bank financial services company which operates more than 1 customer contact location, or is owned by an individual, company, cooperative, or corporation which operates more than 1 customer contact location, or which franchises or otherwise provides the supporting organization or equipment for more than 1 customer contact location, or which services in excess of 10,000 customer accounts per year from 1 or more locations should be considered as a larger participant. Reasoning: Money-sending, payday lending, and other financial services often have an unduly large negative impact on our local and national economies, hitting the poorest among us the hardest, then the middle class, and rarely affecting the rich. It is not acceptable for such companies to hide behind low dollar amount limits or "we don't own the company, or the equipment, we just provide the services that they sell," or "I only have these 3 small stores [square footage is irrelevant] in 3 lower-income neighborhoods...I provide an important service that these poor people need" and other such similar excuses. Of course, this has to be balanced with the fact that the Consumer Financial Protection Bureau has, from its inception, been too small and underfunded, so it cannot possibly police everyone. I suggest that the collection of data regarding online offenders be done in an automated manner, to facilitate policing efforts. I also suggest that the fines be large enough to discourage offenders, despite the small chance that they will ever get caught, that mandatory public service and complete restitution of victims be part of the price for crime, and that the fines be used to supplement CFPB enforcement funding. Thank you.
Comment on CFPB-2011-0002-0001
This is comment on Proposed Rule
Defining Larger Participants in Certain Consumer Financial Products and Services Markets
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