Comment Letter

A coalition of national consumer and civil rights groups wrote letters to three top banking regulators – the FDIC, OCC and Federal Reserve – on the importance of preventing the reemergence of debt-trap bank payday loans. View the letter to the FDIC, letter to the OCC, and letter to the Fed. These letters were signed by Americans for Financial Reform, the Center for Responsible Lending, Consumer Federation of America, The Leadership Conference on Civil and Human Rights, the NAACP, and the National Consumer Law Center (on behalf of its low-income clients). The letters all enclose another...

The Center for Responsible Lending (CRL), as part of a coalition of civil rights, consumer, and labor groups, submitted an official comment letter to the Consumer Financial Protection Bureau (CFPB), excoriating CFPB Director Kathy Kraninger’s plan to gut a 2017 CFPB rule that was issued to stop payday loan debt traps. The coalition’s comment letter, submitted on the last day of the comment period, is a comprehensive rebuttal to Kraninger’s rationales for rolling back the Payday Rule. The letter shows how her proposal fails to account for ample evidence of consumer harm of these 300%+ APR loans...

The organizations listed below submitted this comment letter to the Consumer Financial Protection Bureau (CFPB) on its new leadership’s proposed delay of a 2017 rule the agency had issued to stop payday and car title loans from trapping consumers in debt. The letter rebuts the CFPB’s rationale for proposing a 15-month delay of the payday rule, which the agency is now also moving to gut by removing the common sense requirement that lenders generally verify that borrowers can repay a loan. The organizations joining their voices in opposition to this harmful action are: Center for Responsible...

The Center for Responsible Lending (CRL) and the National Consumer Law Center (on behalf of its low income clients) (NCLC), joined by Americans for Financial Reform Education Fund, the Leadership Conference for Civil and Human Rights, and NAACP, submit these comments in response to the FDIC’s request for information (RFI) on small-dollar lending. We appreciate the FDIC’s ongoing work to encourage banks to meet consumers’ needs and to promote a more inclusive banking system. Indeed, we are very concerned about the persisting racial disparities the new FDIC unbanked/underbanked survey...

The Center for Responsible Lending (CRL) appreciates the opportunity to provide comments on our priorities for the reauthorization of the Higher Education Act (HEA). CRL applauds your initial efforts to tackle these policy reforms in H.R. 6543, The Aim Higher Act. We appreciate your dedication to create a bill that gets our country closer to providing a debt-free higher education for American students. We also appreciate your commitment to underrepresented students demonstrated in provide a more accessible higher education to traditionally underrepresented students by strengthening college...

Self-Help and the Center for Responsible Lending strongly oppose the Department of Homeland Security’s proposed rule to drastically expand the criteria that will be considered to determine whether an immigrant is likely to become a public charge. Being deemed a public charge is of tremendous consequence for individuals and families, as it permits the government to deny someone admission to the United States or a change in status, including lawful permanent residence. Continue reading the comment letter. (PDF)

One of the most prevalent problems with debt collection is harassing communications from debt collectors that violate consumers’ privacy and can cause serious harm to individuals and their families. In the Consumer Bureau’s survey on debt collection experiences, 42% of consumers who had been contacted by a collector in the past year reported that they had asked the collector to stop contacting them. More than a third of consumers were called four or more times a week and nearly one in five were contacted eight or more times a week. Even worse, 75% of consumers who asked to stop receiving calls...

Download the full text of the comment. In determining the capital standards for the GSEs, it is first critical to remember the primary drivers of the 2008 financial crisis and how those conditions have changed, affecting both the likelihood and severity of a future crisis. Next, the assumptions and mechanics of setting the capital regime must be closely examined in order to both set aside sufficient capital and enable the GSEs to provide their essential support for the housing market. Since the cost of holding capital to protect against a future crisis comprises the bulk of the total g-fees...

Today, the Center for Responsible Lending, Americans for Financial Reform, and other leading national labor, civil rights, consumer advocacy, fair housing, and legal services organizations responded in a joint comment to the Office of the Comptroller of the Currency’s (OCC) Advance Notice of Proposed Rulemaking (ANPR) on how the agency should update Community Reinvestment Act (CRA) procedures. The groups pressed the OCC that any changes to the CRA must strengthen -- not weaken -- banks’ obligation to meet the needs of low-income communities and communities of color and that changes must result...

The Center for Responsible Lending (CRL) files this comment in response to the above referenced U.S. Department of Education’s Notice of Proposed Rulemaking (NPRM) which rescinds the 2014 gainful employment (GE) regulations. CRL is deeply troubled by the Department’s decision to do away with these important accountability requirements that protect both the welfare of career training students and the taxpayer resources that support them. The Department has a strong role to play in ensuring that career training programs meet the expectations of enrolled students, who are seeking a better...