AFSA Submits Comment to Mass. on Emergency Legislation April 22, 2020 AFSA’s State Government Affairs (SGA) team yesterday submitted a comment letter regarding Massachusetts HD 5014, which would enact emergency financial protections and forbearance for consumers and small business during the COVID-19 pandemic. While AFSA’s members share the goal of providing relief to borrowers facing financial hardship, the bill as drafted would likely disrupt credit markets and create significant compliance challenges for creditors at a time when resources should be most focused on providing direct consumer relief. Among AFSA’s many concerns with the bill is its wide-ranging scope; as drafted, much of the bill would apply without relation to a consumer’s COVID-19 financial situation. AFSA urged the legislature to revise the bill’s requirements to cover consumers facing demonstrated financial hardships directly attributable to COVID-19. AFSA members are working incredibly hard to help their customers weather this unprecedented storm, however we believe these extreme restrictions would disrupt the entire consumer credit industry and ultimately hurt Massachusetts consumers due to a marked reduction in credit availability. AFSA raised concerns about the bill’s prohibitions on collections, repossession without clear exceptions for protecting assets at risk and voluntary surrender, and interest accrual. AFSA also raised concerns about the bill’s problematic credit reporting provisions. This letter, as well as other SGA comment letters and testimony, can be found on the State Direct Advocacy section of the AFSA website. It can also be found on AFSA’s coronavirus resource page, along with other coronavirus-related tracking resources and comment letters.