National Consumers League applauds House repeal of national banking regulator’s Predatory Lending Rule; Urging Congress to act soon on interest rate cap

June 29, 2021

Media contact: National Consumers League – Carol McKay, 945-3242

Washington, DC—The National Consumers League (NCL) applauds the House for voting for the Congressional Review Act resolution to overturn the OCC’s “fake lender” rule, which allowed predatory lenders to evade state interest rate laws by putting a bank’s name on the paperwork. In a 218-208 bipartisan vote, The U.S. House of Representatives voted to approve SJ Res 15, a resolution under the Congressional Review Act (CRA), which was introduced by Senators Chris Van Hollen (D-MD) and Sherrod Brown (D-OH). A companion resolution was introduced by Rep. “Chuy” García (D-IL). Now that both chambers of Congress have approved this resolution, we look forward to President Biden signing the bill into law.

“We applaud the House’s bipartisan vote to repeal this harmful rule which facilitates rent-a-bank schemes,” said NCL’s Public Policy Manager Sarah Robinson. “This is an important step in preventing predatory lenders from targeting vulnerable communities. We urge President Biden to quickly sign this bill into law to protect consumers.”

NCL was part of a broad coalition of more than 400 organizations representing all 50 states and the District of Columbia calling on Congress to overturn the “fake lender” rule, which threatens to “unleash predatory lending in all fifty states.”

The rushed “fake lender” rule took effect in December and was issued by the Office of the Comptroller of the Currency (OCC). The rule protected “rent-a-bank” schemes whereby predatory lenders (the true lender) launder their loans through a few rogue banks (the fake lender), which are exempt from state interest rate caps. The rule had overridden 200 years’ worth of case law allowing courts to see through usury law evasions to the truth, and replaced it with a pro-evasion rule that looked only at the fine print on the loan agreement.

broad, bipartisan cross-section of experts and officials have called on Congress to repeal the fake lender rule. They include a bipartisan group of 25 state attorneys general, concerned the rule would effectively gut their state usury laws. The Conference of State Bank Supervisors, National Association of Consumer Credit Administrators, National Association of Federally-Insured Credit Unions, Credit Union National Association, Military Officers Association of America, Faith for Just Lending, and many other groups also support Congress overturning the rule.

According to national polling, two-thirds of voters (66%) are concerned about the ability of high-cost lenders to arrange loans through banks at rates higher than the state laws allow.

This victory will stop predatory lenders from charging 100% to 200% APR and make all lenders adhere to state laws.

NCL now urges the Congress to take up the Veterans and Consumers Fair Credit Actand cap interest rates nationally on all consumer loans, including payday and car title loans. It is crucial that the Congress take up this bill that was introduced by Rep. Garcíaand Rep. Glenn Grothman in the last Congress. This is a critical piece of legislation that will protect all consumers from predatory lending. We look forward to working with Congress and our state delegation to pass this important piece of legislation.


About the National Consumers League

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit

Finally, Juneteenth is declared federal holiday

By Sally Greenberg, NCL Executive Director

Juneteenth, or June 19, is now a federal holiday, thanks to an overwhelming Congressional vote and President Biden’s signing it into law in the past two weeks. And it’s a long time coming. The day marks the emancipation of the last enslaved people in America in Galveston, Texas in 1865, over two years after the Emancipation Proclamation was signed by President Abraham Lincoln.

I’ve heard Juneteenth called Emancipation Day, Freedom Day, and the country’s second Independence Day. It surely is one of the most important anniversaries in our nation’s history.

As a Jew who has observed Passover my whole life, the holiday based on the Book of Exodus celebrating the liberation of Jews from Egypt after 400 years of enslavement, I also celebrate Juneteenth.

As I listened to the radio during a road trip, I heard stories about the newly declared federal holiday. I think most importantly, it’s gotten people talking about a conversation America has never really had: truth and reconciliation about the despicable institution of slavery in the United States and its vestiges: a century and a half of Jim Crow segregation, violence, and rampant, entrenched discrimination against African Americans.

Sadly, this is a conversation too many Americans don’t want to have. Oklahoma passed a law outlawing the teaching of “Critical Race Theory” in state schools. In 2020, President Donald Trump issued an executive order excluding from federal contracts any diversity and inclusion training interpreted as containing “Divisive Concepts,” “Race or Sex Stereotyping,” and “Race or Sex Scapegoating.”

What even is Critical Race Theory? The textbook definition is that CRT acknowledges that the legacy of slavery, segregation, and the imposition of second-class citizenship on Black Americans and other people of color continue to permeate the social fabric of this nation.

Half a dozen other states are considering bills similar to Oklahoma’s. Fox News and other right wing media outlets have tried to use phony scare tactics to discourage discussion of slavery and its generations-long aftermath. The problem is that unless we have those discussions, we will never reckon with the reality that so much of our nation was built on the backs of enslaved people, including the White House. Refusing to discuss this our history of enslavement has a term too: “White Fragility,” defined as white Americans feeling discomfort and defensiveness when confronted with information about racial inequality and injustice. So despite Oklahoma’s law, Biden’s declaring Juneteenth as a federal holiday got people talking—and that’s a good thing.

I liked hearing about Civil Rights Activist Opal Lee, who long advocated for the celebration that started in Galveston to be made a federal holiday.

It was also interesting to learn that there’s a growing discontent within the African American community with symbolic gestures like declaring a federal holiday marking the end of slavery.

On that theme, NCL has endorsed HR 40, a U.S. House bill to set up a commission to study the history of enslavement and reparations to families whose relatives were enslaved. Consider these facts about the legacy of slavery:

We thank President Biden for recognizing that Juneteenth needs to be a federal holiday and was long overdue. Equally important is HR 40, which will provide a way forward for this country akin to the Truth and Reconciliation Commission body established by the South Africa in 1995 to help heal the country and bring about a reconciliation of its people by uncovering the truth in the aftermath of Apartheid.

Slavery is a legacy that all Americans, no matter your racial or ethnic background or when your family arrived in the United States, need to confront. We must not let anger, fragility, backlash, or denial prevent us as Americans from taking the time to really learn about and understand slavery, the Jim Crow laws that followed it, and practices, including lynching, that were used as a tool of terror and white supremacy, and the many lasting repercussions of that terrible history.

NCL comments on pediatric COVID-19 vaccines before CDC’s Advisory Committee on Immunization Practices

Media contact: National Consumers League – Carol McKay, 945-3242

Washington, DC—Today, June 24, 2021, NCL Director of Health Policy Jeanette Contreras, submitted written testimony to the Center for Disease Control and Prevention’s Advisory Committee on Immunization Practices in support of pediatric COVID-19 vaccines. Her comments appear below.

José R. Romero, MD, FAAP, Chair
Advisory Committee on Immunization Practices
Centers for Disease Control and Prevention
1600 Clifton Road, N.E., Mailstop A27
Atlanta, GA 30329-4027

RE: Docket No. CDC- 2021-0060; rescheduled from June 18; new docket no. CDC-2021-0034

Good afternoon. My name is Jeanette Contreras, and today I am representing the National Consumers League (NCL), which for over 120 years has championed the overwhelming safety and efficacy of vaccines and promoted vaccine education. Consumer access to these lifesaving medical interventions is critical. I am also speaking today as a mother of two boys, ages 8 and 9. I appreciate the opportunity to provide public comment before this advisory committee.

The U.S. has reached a tragic 600,000 deaths as a result of COVID-19. The virus continues to spread and mutate around the world. Sadly, 330 children and adolescents are among the 600,000 deaths. Although preexisting medical conditions clearly predispose children to severe disease, healthy children are also at risk for severe COVID-19 and multisystem inflammatory syndrome (MIS-C). Though MIS-C is a rare condition associated with COVID-19, Black and Hispanic children are disproportionately affected, making up 64% of the cases observed in children 1-14 years of age.

Though there is reason to be concerned about the increase in cases of myocarditis or pericarditis following the second shot of the Pfizer and Moderna vaccines, consumers should be reassured that the safety monitoring system, Vaccine Adverse Event Reporting System (VAERS), is working as intended. Federal health officials are investigating the rare cases of which the most common symptoms reported were chest pain, elevated cardiac enzymes, ST or T wave changes, dyspnea and abnormal echocardiography or imaging. We applaud the Centers for Disease Control and Prevention (CDC) for releasing clinical guidance to providers alerting them to consider myocarditis and pericarditis in adolescents or young adults with acute chest pain, shortness of breath, or palpitations. So far, 80 percent of patients reported have made a full recovery.

We commend the coordinated efforts of the U.S. Food and Drug Administration and CDC to monitor the safety and efficacy of the vaccine. The COVID-19 vaccine has been administered safely to over 150 million Americans, and we are on target to reach herd immunity by October, with at least 70% of Americans vaccinated. Given the remarkable evidence of safety and efficacy of the COVID-19 in adults, parents should be assured that the vaccine will keep their children safe.

Our children are vaccinated for measles, rubella, polio, diphtheria, typhoid, and other routine childhood vaccines that have for decades prevented deadly illnesses that historically killed millions of children. Today, thanks to vaccine adherence, these illnesses have virtually been eradicated and far rarer than COVID-19. Unfortunately, uptake for routine pediatric immunizations have declined during the pandemic. It is essential we ensure that children are up to date with their vaccines. We are excited that data show the COVID-19 vaccine can safely be co-administered along with routine pediatric vaccinations. As we consider future educational outreach campaigns to increase vaccine confidence, we should encourage families to seek recommended immunizations for their children along with the COVID-19 vaccine.

As states lift public health emergency protocols across the country, too many of our children remain unnecessarily unprotected. According to the American Academy of Pediatrics, as of June 10, over 4 million children have tested positive for COVID-19 since the onset of the pandemic. About 14,500 new child cases were reported last week. We are only beginning to understand the long-term health effects associated with COVID-19, which include extreme fatigue, rapid heart rate, memory loss, gastrointestinal problems and other symptoms that are lasting months after infection. There is a need to collect more data on the long-haul effects on children, and to provide assistance to families who are struggling to find care for their children. We urge the CDC to provide guidance to providers and patients on what to look for when treating children who were previously infected with COVID-19.

As I dropped my 8-year-old at camp yesterday, I was telling him how beginning July 1 we won’t need to wear masks. He asked me “is that because everybody will be vaccinated- except me?” My husband and I are vaccinated, but our family is still at risk of being infected by any of the emerging variants. And when school-aged children return to the classroom in the fall, we may face a spike in pediatric cases.

Through our education and outreach efforts, the National Consumers League will continue to support efforts to vaccinate the nation across lifespan. The absence of a COVID-19 vaccine for pediatric populations will lead to continued transmission and leave children at risk for infection. To achieve meaningful herd immunity, we will need to ensure that children have access to a safe and effective COVID-19 vaccine, and also consider the unique disparities that children of color experience in the face of the pandemic.

Thank you to the Committee for your consideration of our views on this important public health issue.


Jeanette Contreras, MPP
Director of Health Policy
National Consumers League


About the National Consumers League

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit

Maternal vaccines: Safe for mom and baby

Nissa Shaffi

By Nissa Shaffi, NCL Associate Director of Health Policy

In the last few weeks, I’ve noticed an old friend from high school, a mother of an infant, consistently posting anti-vaccine content to her social media. Her posts, which were initially mere reflections, have transformed into full-on conspiracy theories about the safety of the COVID-19 vaccines and cast doubts about to the speed of their approval.

At first, I bypassed these posts, not wanting to create tension with an old friend. However, as they became more inflammatory, I realized that she was essentially spreading falsehoods about vaccines. As a public health advocate, I decided to reach out and offer my perspective. I assured my friend that vaccines have gone through rigorous testing and approval by multiple regulatory bodies in order to be deemed safe for widespread use.

She argued that she went through her entire pregnancy without being vaccinated and that she felt mask-wearing and proper hygiene would offer sufficient protection, ending her thoughts with, “maybe I’m crazy, because I think with this big push, that maybe there’s something else in it that the public doesn’t know about.” While my friend may need more and better information to convince her of the benefits of getting vaccinated, it’s important to know what the science says about vaccine safety for expectant or new mothers.

Per the  Centers for Disease Control and Prevention (CDC) guidance, vaccines are an extremely safe and effective method of avoiding communicable diseases. Certain vaccines for pregnant people not only help the mother stay healthy, but the antibodies developed in response to the vaccine penetrate the placenta and offer protection to the unborn child as well. If you are pregnant or planning on becoming pregnant, the specific vaccines you should receive depend on your age, lifestyle, medical conditions, and other factors. You should consult your doctor for the most up to date information.

The CDC recommends that pregnant women receive two vaccines during the gestational period, the inactivated flu (injection) vaccine, and the tetanus, diphtheria, and pertussis or Tdap vaccine. Vaccines that are not recommended during pregnancy include the nasal influenza vaccine, the human papillomavirus (HPV), measles, mumps, and rubella (MMR), and Varicella (chickenpox) vaccines. Some travel vaccines, such as yellow fever, typhoid fever, and Japanese encephalitis are not recommended during pregnancy, but can be administered based on a health provider’s advice.

Vaccines also offer immense protections via lactation. With exception to live virus vaccines like smallpox and yellow fever, most vaccines provide safety to new moms and babies during pregnancy and postpartum via lactation. There is also evidence that breastfed babies respond better to routine pediatric immunizations than those on formula. The CDC has provided a chart of vaccines that are safe for use in lactation.

An even more convincing case for maternal vaccines are the protections offered against COVID-19.  Data  shows that pregnant people are more vulnerable to severe illness with COVID-19. COVID-19 complications during pregnancy include hospitalization, intensive care, or the use of a ventilator or special equipment to breathe, or illness that results in death. Additionally, pregnant people with COVID-19 are at increased risk of adverse pregnancy outcomes, such as preterm birth.

The CDC has found the COVID-19 vaccine to be safe for pregnant and lactating people. The CDC and Food and Drug Administration (FDA) have safety monitoring systems in place to gather data regarding adverse reactions to vaccines. Currently, neither the mRNA (Pfizer and Moderna) nor the viral vector (Johnson & Johnson) COVID-19 vaccines have demonstrated adverse outcomes and have been deemed safe for use in pregnant populations. While more data are needed to assess potential adverse reactions in pregnant individuals before or early in pregnancy, the agencies have vowed to closely monitor that information.

Expectant and new mothers are often faced with a host of difficult decisions about their own health and the health of their babies. Adding to the uncertainty brought on by COVID-19, it’s understandable that people are apprehensive. Through compassionate and non-judgmental conversations, we can help encourage vaccine confidence. Even though my friend seems adamant in her stance, I still see an opportunity to turn the tide. There are so many great resources to help address these concerns, like these ones by the American College of Obstetricians and Gynecologists and the American Academy of Family Physicians. It’s up to everyday immunization advocates like you and me to quell concerns related to vaccine safety to ensure our friends and loved ones are safe.

National Consumers League applauds the awarding of the prestigious Iqbal Masih Child Labor Award for the Elimination of Child Labor to Norma Flores López and the International Labour Organization

June 11, 2021

Media contact: National Consumers League – Carol McKay, 945-3242 or Taun Sterling, 207-2832

Washington, DC—The National Consumers League (NCL), America’s pioneering consumer and worker advocacy organization and a leader in the fight to reduce child labor globally, welcomes the awarding of the Iqbal Masih Child labor Elimination Award to the Norma Flores López and the International Labor Organization on Thursday.

Iqbal Masih, for whom the award was named, was sold into slavery in his native Pakistan as a rug weaver at age 4, and escaped his captors at age 10. He became a prominent voice against child labor before he was murdered for his activism at age 12.

Norma Flores López, who is a member of NCL’s Board of Directors, works closely with NCL on the Child Labor Coalition (CLC), which NCL founded and has co-chaired since 1989. The following statement is attributable to NCL Executive Director Sally Greenberg:

Norma began working in U.S. fields as a small child, and as a teenager began to speak out against the exploitation of farmworker children – something NCL and the CLC has combatted for decades. She has been a tireless advocate against child labor and has shared her experiences and expertise at numerous international conferences, in newspapers, and on television news magazines, including 60 minutes. Today, Norma heads the CLC’s Domestic Issues Committee, helping us to develop strategies to equalize protections for children who have entered work at early ages. We’re so pleased that Norma’s passion and commitment for protecting children has been recognized with this prestigious award. NCL also works closely with the International Labour Organization, and applauds its recognition as a leading player in the fight against child labor.


About the National Consumers League

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit

June 10 testimony before FDA’s Vaccines and Related Biological Products Advisory Committee

Media contact: National Consumers League – Carol McKay, 945-3242 or Taun Sterling, 207-2832

Washington, DC—Today, June 10, 2021, NCL’s Associate Director of Health Policy Nissa Shaffi, testified before the Food and Drug Administration’s Vaccines and Related Biological Products Advisory Committee, about the ongoing rollout of COVID-19 vaccines for pediatric populations. Her testimony appears below:

Arnold Monto, M.D., Acting Chair
Vaccines and Related Biological Products Advisory Committee
Center for Biologics Evaluation and Research
Food and Drug Administration
10903 New Hampshire Ave, Silver Spring, MD 20993

RE: Docket No. FDA- 2021-N-0458; for Vaccines and Related Biological Products Advisory Committee

Good afternoon. My name is Nissa Shaffi, and I am representing the National Consumers League (NCL). I have no conflicts of interests regarding today’s remarks.

The National Consumers League was founded in 1899, by the renowned social reformer Florence Kelley. General Secretary Kelley’s support of vaccinations played a key part in mitigating a critical smallpox outbreak towards the end of the 19th century, and her stalwart advocacy for immunizations has informed NCL’s bedrock principles for vaccine education, confidence, and safety.

122 years later, we are honored to persist in our pursuit to advance vaccines as vital public health interventions, and we extend our gratitude to the Vaccines and Related Biological Products Advisory Committee for the opportunity to present comment during this public hearing session.

Emergency Use Authorization (EUA)

NCL appreciates that the FDA recognizes that Emergency Use Authorization is not intended to replace the rigor of full approval, and that randomized clinical trials are critically important for the definitive demonstration of safety and efficacy of a treatment.

The diligent review and public engagement that went into the EUA process for the COVID-19 vaccines currently available have helped our nation reach key milestones in immunizations.

As our adult populations have benefitted from these critical public health efforts, we are energized to extend that momentum towards our youngest citizens. Through our education and outreach of consumers, we support FDA in its efforts to develop a safe, effective, and expedited pathway towards a COVID-19 vaccine via an EUA to help prevent the spread of the virus in pediatric populations.

Safety and Effectiveness

We have great trust in the FDA’s safety monitoring systems and call on the Agency to perform ongoing post-market surveillance to ensure the vaccine’s continued safety and efficacy.

As we’ve observed with recent vaccine safety concerns, consumers rely heavily on public health agencies to communicate and respond to any potential adverse events regarding the COVID-19 vaccine. We call on the FDA to continue to sustain its robust interagency collaboration as we endeavor to vaccinate the nation.

Pediatric Population Vaccine Uptake

Although children are at a lower risk of COVID-19 compared to adults, and tend to experience milder symptoms, pediatric populations now account for 22% of new COVID cases, compared to 3% last year. As with adults, children and adolescents with underlying chronic health conditions are at higher risk for COVID-19-related hospitalization and death.

The absence of a vaccine for pediatric populations will lead to continuing transmission that will consistently put children at risk for infection.

Furthermore, vaccine uptake for routine pediatric immunizations have declined dramatically during the pandemic. It is essential for public health officials, advocates, and parents to ensure that children are up to date with their vaccines, and that children eligible for the COVID-19 vaccine receive their shots. Data shows that the COVID-19 vaccine currently available for children ages 12-15 is safe and effective, and has been recommended to be co-administered along with routine pediatric vaccinations.

Health Disparities

While COVID-19 has impacted the entire country, it has largely devastated communities of color. Children of color, specifically Black and Hispanic youth, have been especially vulnerable. This has been even more apparent with the prevalence of Multisystem inflammatory syndrome in children, a rare but serious COVID-19-associated condition, that has been observed in children 1- 14 years of age, 64% of which were reported to be Black or Hispanic.

To achieve meaningful herd immunity, we will need to ensure that children have access to a safe and effective COVID-19 vaccine, and also consider the unique disparities that children of color experience in the face of the pandemic.

Thank you to the Committee for your consideration of our views on this important public health issue. 


Nissa Shaffi
Associate Director of Health Policy
National Consumers League


About the National Consumers League

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit

NCL concerned as Senate bill puts consumers at risk from unregulated CBD

Media contact: National Consumers League – Carol McKay, 945-3242 or Taun Sterling, 207-2832

Washington, DC—On May 19, Senators introduced the Hemp Access and Consumer Safety Act (S. 1698) which directs the U.S. Food and Drug Administration (FDA) to regulate hemp-derived cannabidiol (CBD) products as dietary ingredients or supplements. The National Consumers League (NCL) has long been concerned about the risks posed to consumers by unapproved cannabis-derived products. There is little research on the health and safety of CBD products, and as such the NCL does not support any legislation that would bypass the FDA’s regulatory authority and rigorous scientific review.

Currently, manufacturers and distributors of products containing CBD can petition the FDA for review and approval of a new ingredient as a dietary supplement (21 U.S.C. 350b). This approval process requires manufacturers and distributors to submit scientific data showing that the product is generally regarded as safe (GRAS). “Not only is there insufficient data to designate CBD products as GRAS, the FDA needs further data to determine safe dosage and concentration levels in order to set manufacturing and labeling requirements that ensure consumer safety,” said Jeanette Contreras, NCL Director of Health Policy.

As demonstrated in a white paper published by NCL, companies selling CBD products often focus their research efforts on weak and inexpensive studies, and then use the results for marketing purposes. “Current studies have not enhanced our scientific understanding of CBD, and policymakers should focus on incentivizing further clinical studies to bring new proven medical treatments to patients,” said Contreras. By mandating the FDA to regulate CBD as a dietary ingredient, S. 1698 would only further incentivize CBD manufacturers to forego rigorous clinical trials and the development of FDA-approved medicines. Easier approval as a dietary supplement will disincentivize real scientific research into any potential health benefits or risks of CBD products.

Under S. 1698, CBD manufacturers that make unwarranted claims of treating medical issues will seek expedited approval for their products as dietary supplements, rather than as drugs. We should be encouraging the development of new cannabis-derived medicines that have gone through the rigorous processes of randomized controlled trials and FDA approval. Considering the lack of existing research on CBD, this bill classifying CBD products as dietary supplements would irresponsibly lead to increased consumption of these products and limit the future development of cannabis-derived FDA approved treatments—while putting consumers at risk.


About the National Consumers League

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit