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The Community Financial Services Association of America an industry group for payday and small-dollar lenders called the proposed rule a "staggering blow" that will cut off consumers' access to credit.

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Requirement To Assess Borrowers' Ability To Repay Consulting Lender's Own Records Costs to Small Entities Obtaining a Consumer Report From a Registered Information System Costs to Small Entities Obtaining Information and Verification Evidence About Income and Major Financial Obligations and Making Ability-to-Repay Determination Costs to Small Entities (a) Obtaining Verification Evidence (b) Making Ability-to-Repay Determination Developing Procedures, Upgrading Systems, and Training Staff ii.

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