CFA joined the Center for Responsible Lending (CRL), the National Consumer Law Center (NCLC) (on behalf of its low-income clients), and the National Fair Housing Alliance (NFHA) on comments in response to the Proposed Interagency Guidance on Third-Party Relationships. The comments outline the groups’ deep concern for the proposal’s failure to highlight the significant risks associated with high-cost lending involving third-party relationships. Although the proposal states that the guidance is “especially important” for “relationships that entail greater risk” and for those that “involve critical activities,”  it is silent on high-cost lending, even as several FDIC-supervisee banks are currently enabling high-cost lending through rent-a-bank schemes. Four of these schemes are even current subjects of state enforcement actions or investigations – clearly posing risks to the banks and consumers alike. The comments called on the FDIC to take immediate action to stop these harmful schemes and that the agencies ensure that this joint guidance is not, by its silence, interpreted as permission for banks to enable predatory lending through rent-a-bank schemes.