Permanent Director Kathy Kraninger is seeking comment on two changes—one would delay the effective date of the underwriting provisions of the rule for an additional 15 months to November 2020 and the other would rescind the ability-to-repay requirements.

Kraninger has questioned the research upon which the Cordray-era rule was based.

But the state attorneys general said that research was meticulously documented and t the mere fact that the agency's leadership has changed is not an adequate reason under federal law to delay or rescind the rule.

They said that the research demonstrated that while the payday lending industry would bear the cost of implementing the new rule, the benefits to consumers outweighed those costs.

And they said that the August 2019 effective date gave lenders adequate time to comply with the 2017 rule.

The state officials said they are particularly concerned because they share the CFPB's responsibility to enforce the rule.

"The delay in the Underwriting Protections will leave the citizens of our states unprotected from many types of exploitative loans and could embolden lenders who would seek to circumvent the laws of those states with strong protections against such loans," they said.

But the president of the Consumer Financial Services Association of America, which represents payday lenders, said that his industry already is heavily regulated.

"These lenders are already subject to significant and extensive federal, state, and industry regulations," Dennis Shaul told the CFPB.

And he said the compliance date should be extended.

"If the compliance date is not delayed, lenders will expend significant resources and time to comply with a rule that the Bureau may ultimately conclude lacked valid justification to begin with," he wrote.

And he went on to say that the bureau should re-write the entire payday rule.