CFA and other advocates requested that the Office of the Comptroller of the Currency extend the 45 day comment period on the notice of proposed rulemaking “National Banks and Federal Savings Associations as Lenders” to 90 days. A 45-day comment period is an unreasonably short amount of time to develop comments on a proposal that would have far-reaching consequences on consumer lending and state interest rate caps developed to protect borrowers from predatory, high cost loans, particularly while the country is in the midst of a national pandemic.