PACB Letter to PA Human Relations Commission
April 11, 2005
Homer C. Floyd
Executive Director
Pennsylvania Human Relations Commission
PO Box 3145
Harrisburg, PA 17101-3145
VIA EMAIL TO: c-rhess@state.pa.us
Dear Mr. Floyd:
Thank you for the opportunity to comment on proposed guidelines developed by the Commission to address predatory lending. We also appreciate the ability to email our comments to the Commission a day past the official deadline so that our counsel and staff had ample opportunity to review the guidelines and prepare what we hope is a thoughtful and helpful response.
As an association of almost 200 community-oriented financial institutions, PACB welcomes the opportunity to work with any and all interested parties to ensure consumers are protected as much as possible while also ensuring that legitimate lenders can continue to provide credit with sure and certain standards.
PACB abhors predatory lending and believes that existing state and federal laws and standards should be fully applied and enforced. We also believe that financial literacy educational efforts are critical so that consumers are better informed and able to protect themselves from unscrupulous lenders.
Community banks are highly regulated entities by both the state and federal governments and we are held to our own high standards within our communities. Many of our institutions have been in business for over 100 years and in some cases, 150 years. Collectively, our members have existed for 23,000 years. We have been successful by understanding and serving our communities and respecting our customers.
Our counsel, Shumaker Williams, P.C., has prepared the attached comments in reaction to the Commission's proposed guidelines. Having only received the proposed guidelines in March, we are uncertain how they were developed. Was there industry and consumer input as well as input from state and federal regulators, particularly the Pennsylvania Department of Banking which recently concluded two comprehensive Task Forces that had a great focus on this very issue? Any guidelines the Commission may propose must be in agreement with state and federal laws and standards and it is our great concern that these guidelines are not.
It is with the spirit of cooperation and a shared goal of better serving Pennsylvania's communities that we offer these comments. Should you have any questions, please do not hesitate to contact our counsel, Steve Lovejoy, who may be reached at (410) 825-5223.
Sincerely,
Frank A. Pinto
President/CEO
cc: The Honorable Gibson Armstrong
The Honorable Michael Stack
The Honorable George Hasay
The Honorable Joseph Markosek
The Honorable William Schenck
Paul Wentzel
Shumaker Williams, P.C.