The credit union short-term lending model is consistent with the Consumer Financial Protection Bureau's objectives of protecting consumers from predatory payday lending, CUNA Assistant General Counsel Luke Martone said in a letter to the CFPB submitted Monday.

CUNA presented the position to CFPB in response to the agency's January field hearing on payday lending in Alabama.

The NCUA's Short-Term, Small Amount Loan program was held up by CUNA as a model for responsible payday lending. The program restricts credit unions to principal amounts between $200 and $1,000, maximum six-month terms, application fees of $20 or less, and a restriction against rolling over the loan.

State-chartered credit unions are not eligible for the program, but many offer similar programs, such as the Better Choice loan option at Alabama's Listerhill CU, which provides short-term loans for between $250 and $500 with an 18% APR and 30-day repayment term, and also do not permit rollovers.

The CFPB's deadline for comments submitted on payday lending was Monday.