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Letter to the CFPB Regarding Ongoing Rulemaking on Debt Collection

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...

Congress Must Act to Solve Student Loan Debt Crisis and Close the Racial Wealth Gap

Existing racial wealth gap increases burden of student loan debt on Black families and communities: This means families of color are more likely to need to borrow for higher education, will have less income with which to pay it, and have less of a cushion to withstand future financial shocks, thus contributing to a higher likelihood of delinquency and default...

Priorities for the Reauthorization of the Higher Education Act (HEA)

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...

Strong Opposition to Proposed Changes to the Public Charge Guidelines

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...

Comments on Enterprise Capital Requirements FHFA RIN 2590-AA95

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...

Comment: OCC Should Not Weaken Community Reinvestment Act

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...

Comment to the OCC in Strong Support for Effective Enforcement of the Community Reinvestment Act

These comments are submitted on behalf of the National Fair Housing Alliance (NFHA) and the Center for Responsible Lending (CRL) to express our organization’s strong support for effective enforcement of the Community Reinvestment Act, and our concern about the approach proposed by the OCC in the above-referenced Federal Register notice, dated September 5, 2018, entitled “Reforming the Community Reinvestment Act...

Let My People Go: South Dakotans Stop Predatory Payday Lending

A 30-minute documentary produced by the Center for Responsible Lending, in cooperation with South Dakotans for Responsible Lending Before November 2016, payday and car title lenders in South Dakota charged annual interest rates up to 574%, trapping people in debt and often ruining their financial lives. The state legislature wouldn't pass reform, so South Dakotans put a 36% interest rate...

New Jersey Must Act to Address Student Loan Crisis

In the last decade, student loan debt has exploded, directly impacting the lives of millions of Americans and leaving its mark on the entire economy. There are currently over 44 million Americans with student loan debt. With the costs of higher education continuing to rise at alarming rates and a college education becoming a requirement for more and more jobs...

Testimony: Ensuring Consumer Protections in Financial Markets of the Digital Era

This important hearing addresses how technological innovation has resulted in the development of new services and delivery platforms by both traditional financial institutions and non-bank fintech companies. The rapid expansion of market participants and their products has brought new opportunities, as well as significant consumer protection concerns, to the financial marketplace. In my written testimony I will discuss in detail...

Comment on U.S. Department of Education’s Notice of Proposed Rulemaking Rescinding the 2014 Gainful Employment Regulations

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...

Comment: Protect the Welfare of Career Training Students and Taxpayer Resources

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...

Amicus Brief in Support of D.C.’s right to Pass Laws Protecting Against Abuse of Student Loan Repayment Plans

The brief filed in Student Loan Servicing Alliance v. Taylor, et al. urges the court to reject the plaintiff loan servicer association’s “federal preemption” argument, which claims that existing federal law bars states and the District from engaging in any regulatory oversight of loan servicers. As the brief highlights, this preemption argument is legally unfounded and unwise. In fact, D.C.’s...

Testimony: The GSEs and Ginnie Mae Provide Important Access to Mortgage Credit in Underserved Communities

Both the GSEs and Ginnie Mae continue to provide critical mortgage capital to underserved communities. The GSEs purchased more than two million homes and refinance mortgage loans in 2015, including almost half a million loans to low- and moderate-income borrowers, nearly 400,000 loans to borrowers of color and over 300,000 loans to borrowers living in rural areas. At the same...

Lessons from the financial crisis: The central importance of a sustainable, affordable and inclusive housing market

On this tenth anniversary of the financial crisis, there have been many retrospectives on the US government’s response to that catastrophe, with more to come. The commentary to date has largely focused on the extraordinary measures taken to prevent a much deeper collapse of the American and global economies. Measures were implemented to address the immediate crisis and reduce the...

Comment: Unscrupulous For-profit Colleges Must Be Held Accountable for Their Predatory Tactics

The Center for Responsible Lending (CRL) files this comment in response to the U.S. Department of Education’s proposed rule that would amend the Borrower Defense to Repayment provision of the Higher Education Act (HEA) and rescind and rewrite previously promulgated regulations from 2016. CRL is extremely concerned about the Department’s decision to rewrite rules meant to protect students and taxpayers...

Comment on the Proposed Plan to Rescind and Rewrite 2016 Borrower Defense to Repayment Provisions

The Center for Responsible Lending (CRL) files this comment in response to the U.S. Department of Education’s proposed rule that would amend the Borrower Defense to Repayment provision of the Higher Education Act (HEA) and rescind and rewrite previously promulgated regulations from 2016. CRL is extremely concerned about the Department’s decision to rewrite rules meant to protect students and taxpayers...

Debt and Disillusionment: Stories of Former For-Profit College Students as Shared in Florida Focus Groups

Florida is fertile ground for studying for-profit education, given the industry’s outsized presence there and a weak state regulatory environment. In the early summer of 2017, The Center for Responsible Lending (CRL) conducted focus groups in Orlando, Florida with 75 individuals who had attended for-profit colleges within the last 10 years and borrowed to finance their education. The research sought...

Protecting Servicemembers from Abusive Financial Practices

"The undersigned consumer, community, and civil rights organizations write to urge the Consumer Financial Protection Bureau to reverse its recent decision to suspend the supervision of payday, car title, and other lenders for violations of the Military Lending Act (MLA). We also urge the Department of Defense to ensure that the Military Lending Act is vigorously implemented without exemptions or...

Broad Coalition Urges Regulators and Banks to Avoid a Return to Toxic Loans that Trap Consumers in Debt

Consumer, civil rights, faith, and community groups are urging the FDIC Chair in this letter to keep in place the agency’s guidance urging banks to not sell these toxic loan products, which are harmful to consumers, banks’ reputation, and its safety and soundness. The coalition’s letter also calls for the FDIC to ensure small dollar installment loans are capped at...

Power Steering: Payday Lenders Targeting Vulnerable Michigan Communities

In recent years, payday lenders have drained over half a billion dollars in fees from Michigan consumers to out-of-state companies. By charging APRs over 340%, payday lenders cost Michigan consumers over $94 million in 2016 and over $513 million over the past five years. Over two-thirds of Michigan payday stores have headquarters out of state. Michigan payday lenders disproportionately locate...

Policy Brief: What Happened with Payday Loans in Ohio?

In 2008, the majority of Ohio voters affirmed capping the cost of payday loans in the state to 28% interest, inclusive of all fees and other charges. Since that time, payday and car title lenders have evaded the voter-mandated cap, engaging in schemes to charge rates reaching over 300% annual percentage rate (APR), and even higher than 500% APR. In...

North Carolina Legislative Update August 16, 2018

Dear Coalition Supporters, This update covers important predatory lending developments over the past few months, including action at the NC General Assembly, challenge of the payday rule in Congress (spoiler, we won!), threats to our state usury cap, rollback of federal student loan protections, and recent CRL research. NC General Assembly: What Happened? House Bill 810, backed by the NC-based...
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