Research & Policy

H.R. 1004 will significantly undermine federal agencies’ ability to engage and inform the public in a meaningful and transparent way regarding its work on important science-based rulemakings that will greatly benefit the public. As a result, the bill will lead to decreased public awareness and participation in the rulemaking process in direct contradiction of the Administrative Procedure Act and agencies’...

H.R. 998 would establish a new bureaucracy empowered to dismantle long-established science-based public health and safety standards and would make it significantly more difficult for Congress and federal agencies to implement essential future protections. Along with previous bills that have passed the House and the President’s Executive Orders instituting a regulatory freeze and requiring the removal of two rules for...

With little difference across party lines, Coloradoans expressed their strong support for a proposal requiring debt buyers, companies that buy old debts and attempt to collect on them, provide appropriate documentation for the debts they collect and sue on. Survey respondents were asked this question: Would you support or oppose a law requiring debt buyers to provide documentation to the...

Petitioners argue that the Budget Rules are arbitrary and capricious and unsupported by either the language of the statute or the record. This is not the case. The record abundantly supports each feature of the Budget Rules. In fact, the Budget Rules are a textbook balancing act by the Federal Communications Commission of the competing goals of the statute: to...

Students at Colorado’s for-profit colleges have less favorable outcomes in comparison to their peers at public and private non-profit institutions according to several key indicators, and the impact is greater on students of color. This report uses the data released from the US Department of Education (College Scorecard, September 2015) and compares public, private, and for-profit institutions (also referred to...

The Center for Responsible Lending (CRL), The Leadership Conference on Civil and Human Rights, and the NAACP have sent a letter to Comptroller of the Currency Thomas J. Curry urging him not to offer national charters to financial technology firms, which could severely undermine state oversight and state laws that protect consumers and small business owners from abusive financial products...

Over 250 consumer, civil rights, and community groups wrote this letter to the Office of the Comptroller of the Currency to express strong opposition to the proposed new federal nonbank lending charters that would enable lenders to avoid state interest rate caps, other state protections, and state oversight. State laws often operate as the primary line of defense for consumers...

Payday and car title loans are small-dollar, high-cost products that thrive on keeping consumers in a cycle of debt. With lenders doing essentially no underwriting, consumers find it easy to obtain these loans, often marketed as a solution to financial emergency. However, the unaffordability of the loan and the lenders extreme leverage over the borrowers – either through direct access...

Six years after the Great Recession, American households continue to struggle with consumer debt. According to data reported by the Urban Institute, approximately 77 million Americans – 35 percent of adults with credit files – have debt in collections reported on their credit files. These Americans carry about $1,349 in debt. About 31 percent of Colorado residents have debt in...

The 49 consumer, civil rights, small business, and other community organizations signed on to this letter to express strong opposition to new federal nonbank lending charters that would enable chartered entities to avoid state interest rate caps, other state consumer protection laws, and state oversight, putting consumers and small businesses at risk. The Office of the Comptroller of the Currency...

Lenders can and do make non-covered loans without regard to the borrower’s ability to repay as scheduled, and doing so can be highly profitable. In particular, high-cost loans provide a significant disincentive against lending based on ability to repay, even absent a coercive repayment mechanism or security. When rates are high, lenders can profit despite significant defaults and can even...

The Federal Deposit Insurance Corporation's (FDIC) proposed guidance provides a framework that will require banks to place more stringent requirements on the institutions that they conduct business with. However, as written, the proposed guidance will still enable consumer harm and allow FDIC-supervised institutions to engage in risky relationships with third parties via rent-a-bank lending. We are deeply concerned about the...

The Federal Housing Finance Agency (FHFA) should consider the impact credit risk transfer structures might have on borrowers. In bringing in private capital, FHFA should be careful to ensure that FHFA does not exchange access to credit or borrower protections for the capital the private market offers. We are concerned that the credit risk transfer programs have the potential to...

The California State Legislature and the California Attorney General, Kamala Harris, both submitted comments to the Consumer Financial Protection Bureau in favor of strengthening the proposed rule on payday and car-title lending. Download both of the letters with the link above to read the key points laid out to curb these predatory lending practices.

The Consumer Financial Protection Bureau’s (CFPB or the Bureau) proposed rule to address payday, vehicle title, and other certain high-cost installment loans marks the culmination of over four years of extensive information gathering and data analysis by the Bureau. We thank and commend the Bureau for this work, which has resulted in a robust record of evidence that strongly supports...

The Consumer Financial Protection Bureau’s (CFPB or the Bureau) proposed rule to address payday, vehicle title, and other certain high-cost installment loans marks the culmination of over four years of extensive information gathering and data analysis by the Bureau. We thank and commend the Bureau for this work, which has resulted in a robust record of evidence that strongly supports...

This analysis provides a summary of the outline of proposals that the CFPB is considering to address debt collection and CRL’s initial reactions to it. As we review the proposal more closely, our reactions may evolve.

The 2015 mortgage data submitted by lenders under the Home Mortgage Disclosure Act (HMDA) reflects a market that troublingly continues to underserve important market segments. For people of color and low- to moderate-income families, access to credit remains tight. The data shows how lenders and secondary market actors underserve these consumers even as large banks continue to have access to...

The Center for Responsible Lending strongly supports allowing former ITT students access to the Guaranty Fund. Over the past few years, CRL has been engaged in research and policy regarding for-profit institutions of higher education. During the 2016 legislative session, the Center for Responsible Lending submitted written testimony in support of SB 427, An Act Concerning Higher Education – Institutions...

The undersigned Center for Responsible Lending (CRL) and National Consumer Law Center, on behalf of its low income clients (NCLC), write to comment on the update to the Uniform Interagency Consumer Compliance Rating System (CC Rating System) by highlighting three areas of particular concern: Overdraft practices Loans with a total cost of credit exceeding 36% annual percentage rate (APR) Bank...

The undersigned consumer protection, civil rights, and legal services groups write to express our significant concerns with the outline of proposed regulations on debt collection issued by the Consumer Financial Protection Bureau on July 28, 2016. The proposal represents a missed opportunity to fundamentally improve protections for consumers victimized by predatory debt collection practices. Some of the proposed changes will...

Download the written testimony of Whitney Barkley-Denney submitted in advance of the September 14 hearing on interstate reciprocity agreements in higher education.

The Financial CHOICE Act attacks the CFPB's structure and authority and would frustrate the CFPB's ability to fulfill its mission. Title III of the bill is aimed at obstructing the CFPB's ability to protect consumers from predatory financial products and practices. This title severely weakens the CFPB’s structure and authority in the following ways: Changes the structure of the CFPB...

We are encouraged that the Department's proposal would generally require all providers of distance education to obtain state authorization in each state where they intend to enroll students. However, we have concerns that distance education students could still be subject to weaker protections under the proposed rule, for the following reasons: The proposal would permit state authorization through the use...

CRL strongly supports the CFPB’s proposed rule to limit pre-dispute mandatory (forced) arbitration clauses in consumer finance contracts. Forced arbitration is a widespread issue affecting a plethora of financial products and services; it impacts the consumers CRL advocates for and implicates CRL’s mission to eliminate abusive financial practices. CRL applauds the CFPB for its efforts to restore consumers’ ability to...