Research & Policy

New Jersey has long been a national leader in the fight against predatory lending which strips wealth from communities. Strong state usury laws protecting New Jerseyans from payday lending in the state save New Jerseyans over $193 million annually. New Jerseyans continue to overwhelmingly support a rate cap on payday and consumer installment loans and want to ensure the strong...

If Treasury and FHFA release the GSEs from conservatorship, they should continue the return-regulated approach FHFA has used effectively in conservatorship. Utility-like regulation would allow the GSEs to continue to operate at low risk and in a way that provides broad access to affordable mortgage credit nationwide. Removing that check on GSE returns on equity would lead to greater risk...

Morning Consult conducted a survey, commissioned by Center for Responsible Lending, of approximately 10,000 registered voters. The poll is presented as a short Powerpoint-style slide deck with key takeaways, charts, and maps. This poll presentation is linked to above and here. Key findings include: An overwhelming majority (82%) of those who have taken out payday loans support an annual interest...

Georgia has long been a national leader in the fight against predatory lending, imposing strict usury limits on small loans. In 2004, Georgia legislators closed loopholes used by payday lenders to charge triple-digit interest rates; they reaffirmed their commitment to keeping payday lending out by increasing fines and criminal penalties for making small loans at illegal interest rates. These laws...

In South Carolina, payday and car-title lenders charge working families 395% interest, creating a debt trap that can keep South Carolina families in a cycle of debt for years. In fact, these lenders drain more than $245 million from South Carolinians, primarily from low-income families and communities of color. South Carolinians want reform that has been proven to stop the...

Morning Consult conducted a survey, commissioned by Center for Responsible Lending, of approximately 10,000 registered voters. The results are presented in categories as short Powerpoint-style slide decks with key takeaways, charts, and maps. Dangers of Rent-a-Bank Schemes Bipartisan Support for Stopping Predatory High-Interest Loans Broad Support for Interest Rate Cap Among Payday Loan Borrowers

For most of Michigan’s history, state laws prevented payday lenders from operating, most recently by limiting interest on consumer loans at 25%. However, in 2005, Michigan became the last state to authorize payday lending when payday lenders pushed for a carve out allowing them to charge rates of 340% APR or higher. Payday lenders drain over $103 million in fees...

Morning Consult conducted a survey, commissioned by Center for Responsible Lending, of approximately 10,000 registered voters. The poll is presented as a short Powerpoint-style slide deck with key takeaways, charts, and maps. Key findings include: Two-thirds of voters (66%) are concerned about the ability of high-cost lenders to arrange loans through banks at rates higher than the state laws allow...

Borrower story from the testimony of Graciela Aponte-Diaz: California borrower story: I currently have an installment loan in the amount of $2600.00 from Speedy Cash . . . . At the same time, I also have [x] $300.00 payday loans from [x] different storefronts in my neighborhood, including Speedy Cash. So basically, I have both a $300.00 payday loan from...

We, the consumer and civil rights groups named above, write to strongly oppose the Federal Deposit Insurance Corporation (FDIC)’s proposed rule on Federal Interest Rate Authority (proposal or proposed rule). The proposed rule would allow predatory non-bank lenders to route their loans through banks to evade state interest rate caps. The proposal is outside the FDIC’s statutory authority; it is...

The undersigned community, consumer, civil rights, faith and small business organizations write to strongly oppose the FDIC’s proposed rule on “federal interest rates,” which threatens to eviscerate state interest rate limits around the country and encourage the spread of predatory lending. Download the letter to continue reading. (PDF)

Morning Consult conducted a survey, commissioned by Center for Responsible Lending, of approximately 10,000 registered voters. The poll is presented as a short Powerpoint-style slide deck with key takeaways, charts, and maps. This poll presentation is linked to above and here. Key findings include: Seventy percent (70%) of voters support a 36% annual interest rate cap on payday and consumer...

Deregulatory measures are not the antidote to the affordable housing crisis in our nation. The government must provide the necessary investments to combat the crisis and ensure that potential regulatory changes enhance equity, not detract from it. HUD and the White House Council must not use the RFI process to undermine important public interest protections, such as civil rights, labor...

Download the amicus brief submitted by the Center for Responsible Lending (CRL) and Cohen Milstein Sellers & Toll PLLC (Cohen Milstein) to the United States Supreme Court in the case of Seila Law LLC v. Consumer Financial Protection Bureau  (CFPB) on behalf of their clients, community development financial institutions (CDFIs) Self-Help Credit Union, Hope Enterprise Corporation / Hope Credit Union...

The Center for Responsible Lending and the National Consumer Law Center (on behalf of its low income clients), as part of a coalition of consumer and civil rights groups wrote the comment letter included on this page, which details the groups' strong opposition to a proposed rule from the Office of the Comptroller of the Currency (OCC)’. The proposed rule...

From the letter: Interest rate limits are the single most effective tool states have to protect their residents from predatory loans. Predatory loans include payday and car title loans that often carry annual interest rates as high as 300% or more. Predatory loans also include high-cost installment loans and lines of credit with rates approaching and well exceeding 100%. These...

What is a “Rent-a-Bank” scheme? In the 1990s-mid 2000s, predatory lenders partnered with banks to evade state interest rate caps. In response, federal regulators, the FDIC and OCC, cracked down on this practice. Now, under the Trump Administration, this scheme is reemerging and going unchecked. In fact, the FDIC and OCC have issued proposed rules that could bless this practice...

From the introduction of the brief: Since the founding of our nation, states have limited interest rates as the primary protection against predatory lending. Evasions of usury laws are as old as the laws, but courts consistently look beyond form to the substance of the transaction to prevent subterfuge. Ever since banks were provided with legislative exemptions from state usury...

From the introduction of the brief: Since the founding of our nation, states have limited interest rates as the primary protection against predatory lending. Evasions of usury laws are as old as the laws, but courts consistently look beyond form to the substance of the transaction to prevent subterfuge. Ever since banks were provided with legislative exemptions from state usury...

For more than a decade, payday loans, car-title loans, and high-cost installment loans in South Dakota have carried charges exceeding 300% annual percentage rate (APR). In 2016, South Dakotans approved lowering the cost of payday loans, car-title loans, and installment loans to an annual interest rate cap of 36%, inclusive of all fees and charges. The vote in favor of...

A few high-cost lenders are evading state consumer protections through rent-a-bank schemes. Through these sham arrangements, these companies are exploding right through the interest rate limits that most states have put in place for good reason, to protect people from high-cost debt traps that drain them of their hard-earned income. In the following states, payday lenders are using banks, which...

Yesterday, the FDIC and OCC released their notice of proposed rulemaking (NPRM) for changes to the Community Reinvestment Act (CRA). This proposal utterly fails to achieve what were supposed to be the primary objectives of rule changes: greater clarity for lenders and better results for low- and moderate- income communities and people of color. It ignores the recommendations of our...

A coalition of 61 consumer, civil rights, and community groups sent letters to three federal bank regulators urging them not to allow their banks to help payday lenders evade state interest rate limits. The groups sent separate letters to the Federal Deposit Insurance Corp. (FDIC), which regulates the only banks currently involved in rent-a-bank schemes; the Office of the Comptroller...

The proposed rule will have a toxic effect on the mortgage lending industry. The Fair Housing Act’s disparate impact doctrine has played a critical role in making fair housing available to all, while at the same time making the lending industry better at evaluating creditworthiness. A ban on unjustified disparate impact has encouraged the lending industry to systematically scrutinize its...

"As pastors and faith leaders, our sacred text teaches us to care for our neighbors and see the dignity of all of God’s people. Of all the issues confronting Americans, none is more basic than that of housing. Whether renting or owning a home, every family needs a place to come home to at the end of the day. It...