The statistics around payday and car title loans are scary:

• • The loans come with interest rates of 300-400 percent on average.

• • The average payday loan customer who borrows $400 for a loan to help them get by until their next paycheck winds up paying back $950 over 11 loan cycles in a year.

• • One in five single-payment car title loan borrowers loses their car.

• • There are more payday lending stores than Starbucks and McDonald’s combined, and they target low-income neighborhoods and communities of color.

If you’re a regular reader of the blog, you know we’ve previously talked about payday loans and how they trap low-income Americans in a cycle of debt. We shared the five things you need to know about payday lending, and we shared Ana Maria’s story and James’ story, thanks to the help of CHN affiliates. Because this is a critical time for stopping the debt trap, we’re bringing the issue up again.

The consumer watchdog agency the Consumer Financial Protection Bureau is now accepting comments from the public on their proposed changes, released in June, to the laws that govern payday, car title, and certain high-cost installment loans. The proposed rule would require lenders to determine whether borrowers can afford to pay back their loans, known as the ability-to-repay requirement.

Check out this video from the CFBP, and see why they compare the payday loan debt trap to getting into a cab for a ride across town, but paying for a cross-country road trip.

While the CFBP proposed rule is a great first step, it isn’t perfect. Several consumer rights groups are concerned that the rule doesn’t go far enough and contains loopholes pushed for by payday lenders. The Stop the Debt Trap Coalition, for example, points out that the proposal exempts six high-cost payday loans from the ability-to-repay requirement and doesn’t go far enough to ensure that, after repaying the loan, the borrower will have enough money left over to cover other basic living expenses without reborrowing. In addition, the proposal requires only that the lender not have default rates above those of other payday lenders.

We need a strong rule, without loopholes, to stop predatory lending and help low-income Americans break out of this dangerous cycle. Submit a comment to the CFPB today telling them to do all they can to stop the unfair, abusive and deceptive practices of payday and car title lenders.  The Stop the Debt Trap Coalition has made it very easy to submit comments. Click on our hyperlink, and you’ll see a box where you can copy and paste in a paragraph just below the box. Ideally, you’ll write something in your own words first, or use your own words entirely. You don’t have to be an expert to submit the comments; it’s very important that many individual comments are received, because the predatory lenders are fighting hard to protect their outrageous interest rates and debt-trapping ways.

Then, check out these great resources for more information on predatory lending practices and what the CFPB is doing to end predatory debt traps:

• • CFPB Proposes Rule to End Payday Debt Traps

• • CFPB Rule on Payday and Car Title Lending: What Works and What Doesn’t

• • Joint Statement: Consumer, Civil Rights and Faith organizations Call the CFPB Payday Rule a Good Beginning