INFiN Statement on CFPB Consumer Advisory Board Meeting

December 10, 2025, Washington, D.C. — INFiN, A Financial Services Alliance, appreciates the opportunity to engage in today’s discussion on the current state of small-dollar products and the evolving consumer financial services marketplace before the Consumer Financial Protection Bureau (CFPB) and its Consumer Advisory Board (CAB).

INFiN Executive Director Ed D’Alessio delivered testimony to the Board, highlighting the pivotal role of small-dollar products in providing financial lifelines to millions of Americans, especially those underserved by traditional financial institutions.

“Consumer demand for small dollar products has never been stronger, particularly as many find themselves in need of access to credit,” D’Alessio noted. “To best benefit consumers, the evolution and growth in the marketplace necessitates a regulatory framework that fosters and balances competition and innovation, while ensuring a level regulatory playing field among products and providers consumers compare and use interchangeably.”

INFiN is hopeful that the CFPB’s CAB meeting signals an intention to revisit and review legacy regulations such as the payments provisions of the 2017 Small Dollar Rule. These provisions, as D’Alessio emphasized in his testimony, no longer reflect the realities of how these products work given significant advancements in data analytics, bank account transparency, and consumer safeguards, which have revolutionized lending practices.

“Small dollar products from non-bank providers remain an essential tool for millions of Americans navigating financial challenges,” D’Alessio added. “By fostering innovation, reexamining outdated regulations, and adopting a fair, data-driven regulatory approach, the CFPB can ensure these critical financial services remain available to those who need them most.”