“This form of irresponsible lending creates a variety of compliance, safety and soundness and reputation risks for both the entity that makes the loans and any other entities associated with them,” the NCLC wrote.

The center said it provides legal expertise on consumer law issues to attorneys, policy makers and consumer advocates. Meanwhile, Credit Union Times was told NCUA Staff Attorney Christie Loizos recently spoke at NACUSO's Business Services Connection in San Diego telling attendees the regulator had received more than 250 comment letters on its proposal to amend the CUSO rule. Loizos said because of the large amount of feedback to read through, a decision will not come until after the first of the year.