These teams emphasized the rulemaking that is extensive for the 2017 Final Rule, spanning several years, 1.4 million reviews, and input from many stakeholders
A small grouping of State solicitors general and consumer advocacy teams generally commented that the Bureau properly analyzed and used the unfairness and abusiveness requirements in promulgating the Mandatory Underwriting Provisions of this 2017 Final Rule. These groups further asserted that the rulemaking record within the 2017 Final Rule detailed harm that is serious people who would happen absent the Mandatory Underwriting Provisions. a customer advocacy team asserted that the required Underwriting Provisions were exactly the form of measure that Congress designed the Bureau to generate, and that when you look at the Dodd-Frank Act, Congress identified consumers that are protecting unjust, misleading, and abusive functions and techniques as a core goal associated with Bureau. Further, the commenter noted that Congress singled out payday advances for unique attention, supplying the Bureau exclusive authority to conduct supervisory exams of 
every provider that “offers or provides to a customer an online payday loan.” 32 Other customer advocacy teams asserted as a whole terms that the Reconsideration NPRM mischaracterized the appropriate analysis of unfairness and abusiveness within the 2017 Final Rule, and therefore the appropriate analysis within the Reconsideration NPRM of unfairness and abusiveness had been inconsistent with Federal Trade Commission precedent, Federal Reserve Board precedent, and intent that is congressional.