Research & Policy

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...

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...

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...

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...

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...