Consumer Finance

CRL monitors developments across the consumer finance sector and acts to protect people’s pocketbooks from financial misconduct so families can build financial stability. This includes advocating for enforcement of laws banning discrimination based on race, national origin, sex, and other protected characteristics. CRL also fights to defend the Consumer Financial Protection Bureau, a crucial government watchdog that was established in the wake of the 2008 Financial Crisis to stop predatory practices. We support the development of policy and regulatory infrastructure needed to ensure an equitable green lending marketplace for all consumers. 

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Credit Bureaus Must Take Action To Correct Credit Report Problems for Transgender and Nonbinary Consumers

Credit Bureaus Must Take Action To Correct Credit Report Problems for Transgender and Nonbinary Consumers

145 organizations sent a letter to the “Big Three” credit bureaus (Equifax, Experian, and Transunion) and to the Consumer Data Industry Association (CDIA), the trade association that represents them, urging them to take needed actions to correct credit report problems for transgender and nonbinary consumers.
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Letters to Congress
Consumer Finance

Data Point: California Appeals Court Ruling Affirms Regulator’s Authority to Curb Bail Industry Abuses

Data Point: California Appeals Court Ruling Affirms Regulator’s Authority to Curb Bail Industry Abuses

In a precedent-setting ruling, the California Court of Appeals at the end of 2021 handed down a decision affirming a broad preliminary injunction against a bail bond company called Bad Boys Bail Bonds. The court prohibited the company from collecting on $38 million in debt from cosigners who borrowed money to gain pre-trial release for their loved ones. The order...
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Policy & Legislation
Consumer Finance

Comment to the California DFPI on Proposed Rulemaking to Require Registration and Reporting for Wage-Based Advances

Comment to the California DFPI on Proposed Rulemaking to Require Registration and Reporting for Wage-Based Advances

The National Consumer Law Center, on behalf of its low-income clients, the Center for Responsible Lending, and the Consumer Federation of California submitted comments to the Department of Financial Protection and Innovation’s (DFPI) proposed regulation governing the registration and data reporting requirements for certain industries. These comments focused on the proposed registration of providers of wage-based advance providers. In these...
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Comment Letter
Consumer Finance

Testimony: Buy Now, Pay More Later? Investigating Risks and Benefits of BNPL and Other Emerging Fintech Cash Flow Products

Testimony: Buy Now, Pay More Later? Investigating Risks and Benefits of BNPL and Other Emerging Fintech Cash Flow Products

On November 2, 2021, Marisabel Torres, director of California Policy, CRL testified before the House Task Force on Financial Technology. Her written testimony as well as her oral remarks are available for download. Watch the live hearing:
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Testimony
Consumer Finance Payday and Other Small Dollar Loans

Concern Regarding Prior CFPB Leadership’s Finding that Certain Earned Wage Access Products are Not “Credit” under TILA

Concern Regarding Prior CFPB Leadership’s Finding that Certain Earned Wage Access Products are Not “Credit” under TILA

The National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending wrote to the CFPB to express serious concerns about two actions that the CFPB took a year ago under Director Kathy Kraninger finding that certain earned wage access (EWA) products are not “credit” under the Truth in Lending Act. These actions and the...
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Letters to Congress
Consumer Finance Payday and Other Small Dollar Loans

Organizations and Academics Urge the CFPB to Regulate Fee-based Earned Wage Access Products as Credit

Organizations and Academics Urge the CFPB to Regulate Fee-based Earned Wage Access Products as Credit

The CFPB should rescind the Bureau’s November 2020 EWA Advisory Opinion or to revise its unsound reasoning to prevent evasions of credit laws. The CFPB should also revisit the December 2020 Compliance Assistance Sandbox Approval Order regarding PayActiv for the same reason, and to order PayActiv to cease misusing the order. We also urge the Bureau to eliminate or significantly...
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Letters to Congress
Consumer Finance Payday and Other Small Dollar Loans

Oportun's Abusive Lending Practices Harm Latino and Immigrant Borrowers

Oportun's Abusive Lending Practices Harm Latino and Immigrant Borrowers

From the coalition letter to Michael J. Hsu, acting comptroller of the currency, Office of the Comptroller of the Currency: We the undersigned community, consumer, and civil rights organizations write to express serious concerns about Oportun’s application to the Office of the Comptroller of the Currency (OCC) for a national bank charter. Exactly one year ago, Oportun made headlines for...
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Comment Letter
Consumer Finance Debt Collection & Settlement

Office of Management and Budget RFI: Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government

Office of Management and Budget RFI: Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government

From the letter to Acting Director Shalanda Young, Office of Management and Budget We the undersigned civil rights and consumer advocacy organizations are writing in response to the Office of Management and Budget’s May 5, 2021, Request for Information on Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government. We applaud the OMB for seeking...
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Letters to Congress
Consumer Finance Mortgage Lending

Comment to the Department of Financial Protection and Innovation on Reining in Abusive Practices in the Bail Bonds Industry

Comment to the Department of Financial Protection and Innovation on Reining in Abusive Practices in the Bail Bonds Industry

The private bail bonds industry is woefully underregulated. Unlawful consumer credit arrangements and debt–collection practices abound, yet no government body is charged with addressing these aspects of bail bonds contracts. DFPI has the authority and the expertise to provide much-needed regulation in this industry and doing so would align with its mission. For the good of bail bonds consumers too...
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Comment Letter
Consumer Finance

Group Comment to the Department of Financial Protection and Innovation on Income Share Agreements (ISAs)

Group Comment to the Department of Financial Protection and Innovation on Income Share Agreements (ISAs)

On September 25, 2020, Governor Newsom signed AB 1864 (Chapter 157, Statutes of 2020), establishing the California Consumer Financial Protection Law (“CCFPL”) under Division 24 of the Financial Code. The undersigned consumer advocates are encouraged to see that the Department of Financial Protection and Innovation (“DFPI” or the “Department”) is seeking input from stakeholders in developing regulations to implement the...
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Comment Letter
Consumer Finance
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