Comment Letter

The ongoing foreclosure crisis has made plain the need for meaningful mortgage servicing standards that apply to mortgages and servicers across the country. Both policymakers and homeowners alike are now familiar with a range of mortgage servicing shortcomings that have made it difficult for borrowers to obtain loan modifications and other loss mitigation options. Consumer protection for servicing is particularly important because, even though borrowers can choose their lender, they cannot controlwho services their loan. One of the challenges raised by borrowers and advocates has been the...

CRL told the CFPB of abusive financial practices against older Americans. More than 13 million older adults live on $21,800 a year or less. Further, the average credit card debt for these consumers is now more than $9,000 – the highest average balance of any group.

The Center for Responsible Lending, Consumer Federation of America, and Empire Justice Center submitted comments to the Federal Housing Finance Agency on a proposed rule for the 2012-2014 Enterprise Housing Goals. "It is critical that FHFA continue to focus on its responsibility of ensuring that the Enterprises serve the entire housing market." The Enterprises can do this while fostering a liquid, competitive and strong housing market.

Prepaid cards are an important new financial product that holds the promise of expanding access to modern electronic transactions to millions of consumers. However, prepaid cards lack consumer protections and some have features that expose consumers to unnecessary dangers. The most important step that the CFPB can take to ensure that prepaid cards fulfill their promise, and to prevent unfair, deceptive or abusive practices, is to ensure that prepaid cards are true to their essence as a prepaid transaction product. Overdraft and credit features must be prohibited on prepaid cards.

The Center for Responsible Lending, Consumer Federation of America and The Leadership Conference on Civil and Human Rights responded to the CFPB's request for comments on qualified mortgages. Much of the comment letter focuses on an appropriate "bright line" debt-to-income ratio standard for QMs. Setting a narrow debt-to-income ratio for QMs would unnecessarily exclude a large share of borrowers from QM protections. This letter supports setting a baseline debt-to-income ratio on QMs while also giving lenders flexibility to go above it by considering other "compensating factors" that affect a...

CRL joined with CFA and NCLC to provide the CFPB (Consumer Financial Protection Bureau) with documentation of bank overdraft practices and their impact on consumers. The CFPB should stop banks from reordering transactions and should prohibit overdraft fees on debit card transactions, which can easily be declined at no cost.

The Federal Trade Commission (FTC) Act makes unfair and deceptive acts and practices (UDAP) unlawful and empowers and directs the FTC to prevent such acts and practices through rule-making and enforcement. The Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") provided clear FTC jurisdiction over most auto dealers, particularly when entering into finance transactions with consumers, while freeing the FTC from the cumbersome procedural requirements that otherwise apply to FTC UDAP rule-makings. In easing these requirements, Congress signaled its intent that the FTC use...

FHFA has the mandate and the opportunity to improve mortgage servicing practices. CRL recommends incentives to encourage better service by loan servicers and to promote more timely and effective loss mitigation, free of abusive and unfair practices.

The Center for Responsible Lending, Consumer Federation of America, Consumers for Auto Reliability and Safety, the National Association of Consumer Advocates, the National Consumer Law Center, and on behalf of its low-income clients the National Council of La Raza have filed the following comments to the FTC in regards to the current state of auto lending and the recent motor vehicle roundtables held across the country. In the particular, the comments urge the FTC to: Prohibit auto dealer interest rate markups; End yo-yo scams; Curb loan packing; and Implement steps to ensure that dealers do...