Research & Policy

A letter from seventeen consumer and civil rights advocacy groups to investor and auto dealer, Warren Buffett, urging him to help end discriminatory auto lending practices in this country. In 2014, Mr. Buffett's Berkshire Hathaway purchased the largest privately-held auto dealership group in the nation, the Van Tuyl Group. This letter calls attention to the widely documented problem of "racially...

This written testimony shares our work and insight into the subject of Raised Bill 5071, a bill that has the potential to cause significant harm to Connecticut residents seeking distance education opportunities. Two of key the consequences of the Uniform State Authorization Reciprocity Agreement (SARA) are: Elimination of local, state-centered control over distance education in the state Holding distance education...

The Holder Rule is one of the most important actions the Commission has ever taken in preventing and remedying unfair and deceptive practices in the marketplace. When a seller of a good or service originates or helps arrange credit, the Rule allows consumers to raise the seller’s misconduct as a basis for bringing claims or defenses against the entity holding...

Unfair debt collection practices, particularly those of debt buyers, undermine individuals' financial security, especially among low-income households and households of color. When people are pursued or sued for debt they do not owe, these unfair collection attempts not only threaten the unnecessary extraction of money from individuals, but also hinder opportunities to build assets for the future. Towards this end...

This letter is in response to the Department of Education's request for comments on the proposed Enterprise Complaint System ("ECS"). As advocates for students, consumers, veterans, faculty and staff, civil rights and college access, the signees believe the systematic tracking and reporting of student and borrower complaints is essential to providing quality customer service, ensuring college and loan servicer and...

Public Opinion Strategies conducted a survey of 400 likely Republican caucus-goers in Iowa. The survey was conducted December 14-16, 2015 and has a margin of error of +4.9% in 95 out of 100 cases. Three hundred (300) interviews were conducted with land-line respondents and 100 interviews were conducted with cell phone respondents. Key findings included: Republican caucus-goers in Iowa are...

This letter urges Chairman Kevin Brady and Ranking Member Sander Levin to reject H.R. 4294, the "SAVERS Act," and support the Department of Labor's (DoL) effort to strengthen retirement income security for working families and retirees. Far from being a pro-retirement security alternative to DoL rulemaking, the legislation would weaken the already inadequate protections afforded by current outdated regulations.

This letter to Chairman Pete Sessions and Ranking Member Louise Slaughter urges a strong opposition to H.R. 766, the Financial Institution Customer Protection Act of 2015, introduced by Representative Luetkemeyer. The bill will hamper critical Department of Justice and banking regulator efforts to detect fraud and money laundering, putting consumers and financial institutions at risk of serious financial loss. It...

The organizations represented on this sign-on letter asked President Obama to oppose any FY 2017 appropriations bills which include inappropriate ideological policy riders. Appropriations bills have been used before to undermine essential safeguards through "policy riders" – provisions that address extraneous policy issues, and are slipped into appropriations bills to win approval as part of must-pass funding legislation. Last year...

As strong supporters of the Department of Labor's (DoL) effort to strengthen retirement income security for working families and retirees, the undersigned on this letter urge the rejection of H.R. 4293, the "Affordable Retirement Advice Protection Act." Far from being a pro-retirement security alternative to DoL rulemaking, the legislation would weaken the already inadequate protections afforded by current outdated regulations...

Public Opinion Strategies conducted a survey of 500 likely voters in Michigan. The survey was conducted December 17-20, 2015 and has a margin of error of +4.3.8% in 95 out of 100 cases. Three hundred (300) interviews were conducted with landline respondents and 200 interviews were conducted with cell phone respondents. Key findings included: There is clear opposition to payday...

The Center for Responsible Lending1 submits this comment to provide additional context about the consumer installment loan market, in particular to highlight issues unaddressed by the proposed settlement with One Main and Springleaf. In this letter, the undersigned organizations bring to your attention three areas of concern that the settlement did not address, but which have a significant impact on...

The Center for Responsible Lending submits this comment to provide additional context about the consumer installment loan market, in particular to highlight issues unaddressed by the proposed settlement with One Main and Springleaf. In this letter, the undersigned organizations bring to your attention three areas of concern that the settlement did not address, but which have a significant impact on...

The 40 undersigned organizations oppose inclusion in any criminal justice reform package of "mens rea" (state of mind) provisions that would make it harder for prosecutors to criminally prosecute companies and corporate executives that engage in criminal wrongdoing. Specifically, there are various mens rea proposals, including mens rea legislation proposed in the Senate, that are premised on the belief that...

On behalf of our millions of members and supporters nationwide, these 45 groups urge the opposition of the so-called "Sunshine for Regulatory Decrees and Settlements Act of 2015" (H.R. 712), which would undermine citizen enforcement of our laws and impede the resolution of consumer protection, anti-discrimination, environmental protection, and other important cases before our federal courts. H.R. 712 targets consent...

More than 250 civil rights, consumer, labor, faith, veterans, seniors, and community organizations, strongly oppose H.R. 4018, the "Consumer Protection and Choice Act." This harmful bill would limit the Consumer Financial Protection Bureau's (CFPB) ability to protect all consumers against high-cost payday, car title, and installment loans. In addition to delaying the Bureau's rule-making for two years or longer, H.R...

Predatory consumer lending is still flourishing in California. Payday lending continues to be pervasive, capturing borrowers who were sold a short‐term loan in a long‐term cycle of debt. But high‐cost debt trap lending has expanded rapidly in the past few years to much larger loans, including some which are secured by and put a borrower’s car at risk. At the...

In Debt Collection Agencies and the Supply of Consumer Credit, Viktar Fedaseyeu examines state-level data to assess the effect of state laws limiting third-party debt collectors on the availability of revolving lines of credit (i.e., credit cards). The debt-buying industry claims that this paper demonstrates that consumers are harmed by these laws and thus regulations should be rolled back, or...

CRL responded to the House Financial Services Committee report on the CFPB and Indirect Auto Lending. We address this response in a letter to House Financial Services Chairman Hensarling and Ranking Member Waters dated and sent on 12/9/15. In the HFSC Report, several assertions are made about indirect auto lending, including arguments opposing CFPB data methodology and an argument that...

We write you to express our concern with pending Senate legislation and recent statements by administration officials in both the U.S. Treasury Department and the White House. Specifically, the Jumpstart GSE Reform Act of 2015, and statements by Secretary Jack Lew, Counselor to Secretary Antonio Weiss, and Mr. Michael Stegman of the National Economic Council opposing greater administrative reforms of...

The organizations represented on this sign-on letter asked President Obama to oppose any appropriations bill that contains inappropriate and ideological policy riders. With the passage of the framework bill for funding the government, has turned to how to allot the monies and what may be attached. Appropriations bills have been used before to undermine essential safeguards through "policy riders" –...

This sign-on letter urges the rejection of any effort to include the "Jumpstart GSE Reform Act" in the omnibus FY 2016 appropriations agreement. While the name and the stated purpose of this bill may sound innocuous, it would effectively hinder rather than advance reform of Fannie Mae and Freddie Mac, increasing the risk of future taxpayer bailouts, and potentially jeopardizing...

Payday loans – whether made online, in stores or by banks – are designed to trap individuals in long-term debt. Data consistently show that the majority of payday loan revenue comes from repeatedly churning borrowers, and that borrowers are typically indebted for most of the year. Recognizing the damaging structure of payday loans and their devastating impact on families' financial...

The undersigned organizations write to urge you to oppose H.R. 1210 (the “Portfolio Lending and Mortgage Access Act”). This bill makes two harmful changes to the Dodd–Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and its implementing regulations: It takes a special exemption designed for more trustworthy small and rural banks and extends it to all banks, regardless...

A recent Lake Research poll finds strong enthusiasm for new mortgage lending rules that require verification of ability to repay. Voters of all political parties express a strong desire to keep these rules in place. More than nine in ten voters (91%) support requiring mortgage lenders to verify a borrower’s ability to repay before making a loan. Nearly three quarters...