Consumer Federation of America (CFA) is pleased to submit written testimony to the Subcommittee on Financial Institutions and Consumer Credit, Committee on Financial Services as part of the Subcommittee’s consideration of current and pending regulations that impact non-depository financial institutions. The harmful practices of payday and auto title lenders, and the importance of effective regulations to protect consumers from abusive practices is of particular concern. The comments provided below address two pending regulatory actions: the working draft of possible payday, auto title and payday installment rule released by the Consumer Financial Protection Bureau (CFPB); and the proposed rule to improve the Military Lending Act under consideration by the Department of Defense (DoD).