Research & Policy

On March 26, the Consumer Financial Protection Bureau offered a first look at proposals under consideration to curb the payday loan debt trap. The consumer agency released information outlining their deliberations at a field hearing in Richmond, VA – at which the agency also heard from a panel of consumer and civil rights advocates, as well as payday industry representatives...

In this letter (2 pages), six consumer and civil rights groups ask Members of Congress to oppose H.R. 685, The Mortgage Choice Act of 2015. The groups argue that the bill would raise the cost of mortgages for millions of prospective homebuyers by allowing higher fees and creating a loophole in the landmark Dodd-Frank Wall Street Reform and Consumer Protection...

In "Do Defaults on Payday Loans Matter?" author Robert Mann uses a difference-in-difference regression-based analysis to analyze "harm" in the payday lending market. He finds that little difference in changes in credit scores between payday defaulters and non-defaulters and uses this as evidence that payday loans do not cause harm. However, this study suffers from significant conceptual and technical flaws...

In "Payday Loan Rollovers and Consumer Welfare," Jennifer Lewis Priestley analyzes proprietary payday loan data for borrowers who received payday loans from 2006-2009 in California, Florida, Kansas, Missouri, Oklahoma, Texas and Utah to estimate the impact of payday rollovers on consumer welfare (as measured by changes in Vantages Score). The author finds that payday borrowers who engage in protracted refinancing...

In this letter (2 pages), 16 consumer, civil rights, and housing groups ask Members of Congress to oppose H.R. 650, The Preserving Access to Manufactured Housing Act 2015. The groups argue that the bill would roll back protections established by the landmark Dodd Frank Wall Street Reform and Consumer Protection Act and hurt low and moderate income families. The groups...

The letter states... On August 20, 2014, the Department received a joint memorandum from the American Bankers Association (ABA) and Consumer Bankers Association (CBA),1 arguing that the Department did not have authority under Title IV of the Higher Education Act (HEA) to promulgate rules on campus banking products of the scope proposed during negotiated rulemaking in spring 2014. The ABA's...

A new bipartisan poll of likely 2016 voters finds that voters across party lines strongly oppose unfair lending practices and support financial regulations and enforcement by the Consumer Financial Protection Bureau. Strong Bipartisan Support Download the full memo (PDF) In particular, voters of all parties oppose a range of common payday lending practices, and strong majorities across party lines want...

In February 2013, the American Fair Credit Council, an association of debt settlement companies, released a report that claimed to assess the outcomes of debt settlement services by the industry. This report, "Options for Consumers in Crisis: An Economic Analysis of The Debt Settlement Industry," was commissioned by the AFCC, and fails to demonstrate that debt settlement leaves consumers better...

This letter strongly urges the opposition of H.R. 527, the Small Business Regulatory Flexibility Improvements Act of 2015 (SBRFIA). SBRFIA expands the reach and scope of the Regulatory Flexibility Act and would increase unnecessary and lengthy regulatory delays, increase undue influence by regulated industries and encourage convoluted court challenges.

Media outlets continue to report on the potential dangers of the rise in subprime auto lending. Auto lenders, particularly in the subprime auto lending market, are increasingly using risky practices to fuel lending growth. The New York Times, Fortune, NPR and other news outlets reported on recent news in the subprime auto loan market, providing opportunities to explain both the...

The auto finance market has grown significantly in the past few years. According to Experian Automotive, outstanding auto loan balances reached a record-breaking $870 billion in the third quarter of this 2014, an increase of 9.9% and 24.5% over the same periods in 2013 and 2012, respectively. As of the end of the third quarter of 2014, loans to consumers...

This letter urges the FHA to reduce the cost of its single-family mortgage insurance premiums to expand access to safer and more affordable mortgages to more creditworthy households. The FHA has twin missions to provide access to mortgage credit and to protect the integrity of the Fund - these missions are best accomplished using a dynamic evaluation of the FHA...

Major consumer groups have submitted comment today urging the Department of Defense to protect the men and women who serve the country by creating strong, new regulations implementing the Military Lending Act (MLA). The Center for Responsible Lending, Consumer Federation of America, Consumer Action, the National Association of Consumer Advocates, the National Consumer Law Center (on behalf of its low...

Dear Secretary Duncan, Attorney General Holder, and Director Cordray: As advocates for students, veterans, consumers, civil rights and college access, we write to express grave concerns about the proposed sale of 56 Corinthian Colleges campuses to ECMC Group, a debt collector and loan servicer. We urge you not to waive liability for any prospective buyer of Corinthian campuses unless the...

Read Lisa Stifler's remarks before the December 2014 CFPB Field Hearing on Medical Debt Collection on the distinct lack of standards for when a bill is sent to a debt collector or reported to credit reporting agencies. These distinctions can result in unique harms to individuals in the credit reporting context. As CFPB research has shown, consumers with medical debts...

Senior Policy Council Maura Dundon submitted testimony to the Department of Education on its 2015 rulemaking agenda.

CRL and seven other civil rights organizations jointly authored a policy brief that shares the adverse impacts students of color experience and a primary impetus for a strong gainful employment rule.

On October 29, the Center for Responsible Lending joined a coalition of consumer and civil rights organization to comment on the proposed changes to the Home Mortgage Disclosure Act (HMDA) reporting requirements. Jointly, the groups applauded the utility and growth of the HMDA – which was created as a legislative response to combat urban disinvestment and the practice of redlining...

By Maura Dundon Originally published by American Banker The Consumer Financial Protection Bureau's recent report on private student loans drew a sharp critique from lenders, who claim that the CFPB unfairly singles out private loans while ignoring problems with federal student loans. While the federal loan program has issues of its own, private student loans have distinct concerns. Congress instructed...

The California Department of Business Oversight (DBO) released data on October 3, 2014 showing the extent to which repeat lending comprises the bulk of payday loan activity. Over 75% of all payday loan fees are from borrowers with 7 or more payday loans in 2013. The Center for Responsible Lending's analysis of DBO's data supports the conclusion that, far from...

Attorneys General representing states in the South, Midwest, Southwest and Northeast stand united in support of progressive reforms affecting for-profit college accountability. In a letter to Members of Congress, the officials wrote, "[E]ach of our offices have encountered far too many former and current for-profit school students who have been harmed by the dishonest and unethical practices of some for-profit...

A post-secondary education is increasingly necessary in order to obtain a high-quality job and a lifetime of financial security and wealth-building opportunities. Many students finance their education through student loans because they see its value as an investment in their future. However, according to the research presented in this paper, the value of that investment is questionable for those students...

The 2013 mortgage data submitted by lenders under the Home Mortgage Disclosure Act (HMDA) reflects a slowly recovering mortgage market that troublingly continues to under-serve important market segments. People of color and low and moderate-income families continue to receive a far lower share of mortgage loans than they have historically and than would be expected based on the composition of...

This comment letter signed by 15 organizations supports the CFPB's proposal to make consumer complaint narratives public, and emphasizes the need to do this in the context of student loans. It also provides recommendations on how the complaint intake process could be improved so that more borrowers would be able to submit problems.