CFA joined more than 50 consumer, civil rights, community and faith- based organizations in opposing the Consumer Financial Protection Bureau’s plans to engage in payday loan disclosure testing. The letter is set in broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from the harms associated with payday lenders’ practice of making payday loans without reasonable ability-to-repay determinations. The groups argue that disclosures would only provide a false veneer of protections that payday lenders would use to bolster their opposition to meaningful consumer protections against unaffordable loans.