Comment Letter

CRL and more than 50 organizations committed to gender justice submitted a comment in support of strengthening the Department of Housing and Urban Development (HUD) Proposed Rule on Affirmatively Furthering Fair Housing, which was published in the Federal Register on February 9, 2023 (HUD Docket No. FR 6250-P-01) (Proposed Rule).

In response to a Federal Trade Commission (FTC) notice that it intends to issue regulation, CRL joined a coalition of consumer groups in calling for FTC action to rein-in junk fees. Among other topics, this comment letter highlights a CRL report on installment loan companies that would tack on credit insurance and “automobile club memberships” – charges that meet multiple characteristics of junk fees, including that they’re often a surprise to the consumer and that their value to the consumer is limited or nonexistent. The letter was also signed by: Accountable.US AKPIRG American Economic...

Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low- income clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submitted comments for the Community Reinvestment Act (CRA) examination of First Electronic Bank. First Electronic Bank helps at least two nonbank lenders make predatory loans at rates up to 180% annual percentage rate (APR) that they cannot legally make directly. The loans that First Electronic Bank...

From the comment: Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its lowincome clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of FinWise Bank. FinWise Bank helps several nonbank lenders make predatory loans at rates up to 160% annual percentage rate (APR) that they cannot legally make directly. The loans that FinWise...

The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund strongly support the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. In November 2020, CRL and Self-Help urged the Fund to adopt several critical consumer protections in the Fund’s certification application. We are very pleased to see that the Fund has proposed to adopt many of those protections, including: Limiting the ability of CDFIs to lend at interest rates that exceed 36% Requiring CDFIs to lend...

A broad coalition of consumer groups filed comments supporting the CDFI Fund’s changes to the application for CDFI certification. In recent years, many harmful financial products have been pushed on underserved communities in the name of “access to credit” and “financial inclusion.” Most CDFIs stay away from these harmful products and are true to their mission but far too many entities have obtained CDFI status despite engaging in these irresponsible financial practices. The coalition supports the Fund’s changes to the CDFI application to close many loopholes that allowed CDFIs to offer...

The National Consumer Law Center (on behalf of its low-income clients), the Center for Responsible Lending, and the National Housing Law Project submitted this comment to the Consumer Financial Protection Bureau in response to a request for information regarding mortgage refinances and forbearances.

Letter signed by 110 national, state, and local consumer, civil rights, legal services, community, public interest organizations, consumer attorneys, and others in comment on the FTC’s Notice of Proposed Rulemaking (NPRM) on the sale, financing, and leasing of motor vehicles by dealers.

Cars are essential for most households in the United States, but access to a safe, affordable vehicle is increasingly limited for many consumers by sharply rising prices, burdensome accompanying debt obligations, and problematic dealer practices. The cost of a vehicle represents such a significant proportion of many American households’ total annual income that over 88% of new car purchases and 45% of used car purchases are financed. Enforcement actions by federal and state consumer protection agencies, as well as private litigation, have highlighted auto dealer practices that exploit the...

The National Coalition for Asian American Community Development (National CAPACD), the Center for Responsible Lending (CRL), and the National Association for Latino Community Asset Builders (NALCAB) are pleased to submit collective recommendations as the Building Back Better for Entrepreneurs of Color partnership to the interagency request for public input regarding the Community Reinvestment Act.