Bill’s Broad Language Could Unintentionally Affect TILA
AFSA’s State Government Affairs team submitted a comment letter to the Rhode Island Senate Committee on Commerce regarding Senate Bill 17, which addresses so-called “junk fees” and deceptive pricing practices.
AFSA expressed concern that the bill’s broad language could unintentionally affect financial institutions already governed by federal laws like the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act (RESPA). These laws mandate clear disclosures of terms, fees, and costs. Without exemptions or safe harbors for entities complying with these federal statutes, S 17 could create conflicting obligations and legal uncertainty for regulated lenders.
AFSA recommended amending the bill to include a provision stating that compliance with TILA or RESPA would be deemed compliance with S 17. This approach, adopted in other states like California, would ensure consumers continue to receive strong protections without imposing duplicative requirements on lenders.
This, along with other SGA letters, can be found on the direct advocacy section of AFSA’s website.
April 28th, 2025
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