Research & Policy

The Paycheck Protection Program (PPP) is a revenue replacement program designed to sustain small business jobs during the ongoing public health and economic crisis. The effect of the crisis on small businesses has been profound—over half of small businesses said the crisis has had a large negative effect on their businesses and 74% of small businesses said they have had...

Nearly forty consumer and civil rights organizations call on the Trump Administration and the Congress to work together and take the following steps to ensure access to the Paycheck Protection Program for underserved businesses and sole proprietors. Set aside $10 billion for use ONLY by Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs), to make this funding available...

CRL is working to monitor the unfolding developments of the COVID-19 pandemic and its financial and economic effects on LMI communities and communities of color. As the response to the crisis continues, CRL is advocating for strong consumer protections and financial relief for the consumers, workers and small businesses that are always among the hardest hit by any national emergency...

CRL's comment to the Small Business Administration on the April 15 Interim Final Rule implementing the Paycheck Protection Program focuses on two key challenges with the PPP to date: The Paycheck Protection Program continues to be disadvantageous to smaller businesses, and businesses without employees. PPP loans can be forgiven if the business is able to use the funds for eligible...

From the letter to Speaker Pelosi, Chairman Scott, and Chairman McGovern: As Congress works to better protect Americans from the economic fallout of COVID-19, the financial difficulties of 44 million student loan borrowers and the effect of this debt on the economy cannot be forgotten. The relief in HEROES, especially the $10,000 of cancellation per borrower, will have a significant...

A joint statement on the choice to narrow student loan debt cancellation in the HEROES Act from Action Center on Race and the Economy, American Federation of Teachers, Americans for Financial Reform, Center for Responsible Lending, Demos, Generation Progress, National Consumer Law Center (on behalf of its low-income clients), Student Borrower Protection Center, Student Debt Crisis.

A majority of Americans across all regions of the US support permanently reducing student loan debt by $20,000 for all borrowers, according to a new bipartisan poll by Lake Research Partners and Chesapeake Beach Consulting. Download the poll results Download the top lines

Americans of all partisan identities,and across all regions of the United States,strongly support enacting new consumer protections on high-interest lending during the coronavirus crisis. Americans are highly supportive of prohibiting all high-interest loans during the crisis and of capping interest rates for consumer loans, according to a new bipartisan poll from Lake Research Partners and Chesapeake Beach Consulting. Download the...

The Small Business Administration Paycheck Protection Program (PPP) has failed to fairly serve businesses owned by people of color, causing spill-over harms throughout communities of color, states, and regions. Businesses owned by people color are a substantial source of income and employment—accounting for more than 8.7 million jobs at total annual payroll of $280 billion, and $1.3 trillion in revenue-yet...

H.R. 748, the Coronavirus Aid, Relief and Economic Security Act (CARES Act)—signed into law on March 27, 2020—offers important benefits for the public health crisis caused by COVID-19. However, the bill fails to provide substantive, comprehensive financial relief for vulnerable families who now face economic challenges, such as unemployment and reduced work hours, as a result of the crisis. It...

From the full comment letter: As more borrowers than ever migrate to online platforms, the Department’s role in ensuring program integrity is even more vital. The consensus language in the NPRM represents the best compromise between industry, innovators, and borrowers. If it is changed at all, it should be strengthened, not weakened. The final rule should include the consensus definitions...

The COVID-19 crisis is having profound financial impacts on families across the country and on the economy overall. With businesses shuttered, and over 22 million unemployment claims filed in the first month of the crisis alone, it is hard to overstate the financial instability and hardship the crisis has produced. These impacts will worsen over time, as immediate income shortfalls...

From the letter to Secretary Mnuchin: The undersigned civil rights, faith, and community development organizations write to seek that you direct the Small Business Administration (SBA) to designate that Community Financial institutions (CFIs) receive one-third of the $30 billion set aside for three groups of lenders—CFIs, small insured depository institutions, and credit unions—pursuant to H.R. 266, the Paycheck Protection Program...

From the letter to Congressional leadership: The undersigned consumer and banking industry organizations write to urge Congress at the soonest possible opportunity to clarify that economic impact payments responding to this public health emergency are exempt from otherwise legally binding garnishment orders. Our organizations have worked together to address this issue and we believe that is possible to protect American...

While we applaud that quick action for student loan borrowers, we are concerned that this unprecedented crisis is affecting many borrowers who have Perkins loans or Federal Family Education Loan Program (FFELP) loans that are not federally owned and who are not covered under the CARES Act. We respectfully request that you take action to enact, as part of your...

H.R. 748, the Coronavirus Aid, Relief and Economic Security Act (CARES Act), signed into law on March 27, 2020, provided for a 6-month suspension and interest waiver on federally-owned student loans. It also halted all involuntary collections on these loans. These provisions only apply to Department of Education-held loans, excluding 1.9 million Perkins Loan borrowers, 5.98 million commercially held FFEL...

Even before the onset of the COVID-19 pandemic, US household debt was on the rise, reaching over $14 trillion. While much of this debt stems from mortgages, a growing amount stems from non-mortgage consumer debt, including student loans, medical debt, credit cards, installment loans, and auto loans. With the number of Americans facing unemployment, lost wages, and depleted savings due...

Housing accounts for almost 20% of our national economy. Disruptions in the housing sector will have a ripple effect across the economy. This crisis lays bare wealth and income inequality, including the racial wealth gap, that worsened in the last crisis and the structural flaws in our economy that produce this inequality. Actions must be taken now to protect financially...

Payday lenders see chaos and crisis as a profit opportunity—this pandemic is no different. In many states, payday lenders are working to be declared essential businesses so that they can continue to prey on families even as financial insecurity increases. However, these loans that trap people in a cycle of debt are never essential--and in a crisis they are even...

From the full comment letter: The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) strongly oppose the OCC and FDIC’s proposed Community Reinvestment Act (CRA) regulations.... The most troubling outcome of theproposed rule is that it would unwittingly sanction redlining. The proposal relies on an overly simplistic evaluation measurethat focuses on the total dollar value of...

Even during the best economic times, overdraft fees are a tremendous drain on working families and often cause irreparable harm. The fees compound into hundreds per year for banks’ most financially distressed account holders and some even end up spending over a thousand dollars in overdraft fees. They drive people out of the banking system altogether, which disproportionately harms people...

On March 26, 2020, five federal agencies (the OCC, FDIC, Federal Reserve, CFPB, and National Credit Union Administration (NCUA)) issued brief joint guidance to “specifically encourage” financial institutions to offer “responsible small-dollar loans” to both consumers and small businesses during the COVID-19 crisis. This guidance contains troubling language that could be read to permit banks to make payday loans. Banks...

A diverse coalition of community organizations signed on to this letter to Congress urging them to protect Americans from price gouging during this unprecedented COVID-19 crisis, by enacting a 36% APR cap on all loans. Congress should amend the Military Lending Act (MLA) to extend to ALL consumers the credit protections provided to members of the Armed Forces and their...

The Center for Responsible Lending (CRL) joined with 26 national civil rights, consumer, housing and labor groups, and 35 state groups in sending a letter to Congress with specific financial policy proposals that help address the needs of families most at risk from the impending economic collapse. A PDF of the letter is included above.

From the letter: We believe such a rulemaking is necessary to provide much-needed clarity to this thus-far opaque part of the U.S. financial system – that is, the manner in which parent companies and affiliates of ILCs are subject to any kind of federal regulatory or supervisory oversight. By contrast, the federal statutory, regulatory and supervisory framework for parent companies...