Research & Policy

In this comment, CRL affirms that limits on loan originator compensation contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act and in Regulation Z are important consumer protections that fundamentally improve the mortgage market, and offers some suggestions for improving standards proposed by CFPB.

The ongoing foreclosure crisis has made plain the need for meaningful mortgage servicing standards that apply to mortgages and servicers across the country. Both policymakers and homeowners alike are now familiar with a range of mortgage servicing shortcomings that have made it difficult for borrowers to obtain loan modifications and other loss mitigation options. Consumer protection for servicing is particularly...

Five years into the foreclosure crisis, borrowers across the country are still struggling with their mortgage payments, and many seek housing counseling to help manage their finances and guide them through the loan modification process. Between 2008 and 2012, the National Foreclosure Mitigation Counseling Program provided foreclosure counseling to nearly 1.4 million homeowners and mortgage-related legal assistance to more than...

Homeville.us By joining Homeville and tweeting, you're standing up for the mortgages we need now. Fair loans that serve all creditworthy borrowers. Designed to last. Recovering the American Dream After years of steady progress, the homeownership rate in America has seen its biggest drop since the Great Depression. Lax lending rules and Wall Street's lust for bad mortgages triggered a...

CRL offers supports the Bureau's consumer protection proposal for mortgage rules and disclosures for high-cost (HOEPA) loans. But it urges CFPB to be vigilant about evasions of HOEPA and to adopt a regulation that is expansive enough to capture all loans structured to evade HOEPA.

Finding the Right Balance Lack of underwriting, not low down payments, caused the current crisis. Strong underwriting is the best way to rein in risky loans—and Dodd-Frank already requires this. As part of implementing the Dodd-Frank financial reform bill, federal regulators are charged with defining a "Qualified Residential Mortgage" or QRM. Government proposals have called for down payments up to...

Many families who can pay their mortgages on time don't have wealth reserves for a large down payment. Decades of lending have shown that low down payment lending can be successful. Excluding millions of good borrowers from the mainstream mortgage market would be a serious mistake—slowing housing recovery and dragging down the economy when we most need healthy growth. With...

Honorable Ben S. Bernanke Chairman Board of Governors of the Federal Reserve System Washington, DC 20551 Honorable Timothy Geithner Secretary U.S. Department of the Treasury Washington, DC 20220 Honorable Thomas J. Curry Comptroller Office of the Comptroller of the Currency Washington, DC 20219 Honorable Martin J. Gruenberg Acting Chairman Federal Deposit Insurance Corporation Washington, DC 20429 Mr. Edward DeMarco Acting...

Read the complete issue brief Read a short summary. Read the letter to regulators from CRL and six other organizations. Federal regulators are currently debating how to define "Qualified Residential Mortgages" (QRMs), a category of home loans established by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Under Dodd-Frank, mortgage lenders that sell their loans into the...

At the root of HR 6139 and similar legislation is an effort by non-bank lenders to circumvent new federal oversight and undermine consumer protections recently provided under recent Wall Street reforms. HR 6139 will needlessly move federal jurisdiction over non-bank financial service providers from the newly created Consumer Financial Protection Bureau (CFPB) to the Office of the Comptroller of the...

CRL told the CFPB of abusive financial practices against older Americans. More than 13 million older adults live on $21,800 a year or less. Further, the average credit card debt for these consumers is now more than $9,000 – the highest average balance of any group.

Bringing the "unbanked" into mainstream banking is good policy only if new account holders are not subject to financial practices that strip funds from these new accounts. Unfortunately, today's mainstream banking environment is fraught with danger for families who do not have a significant cushion of cash at their disposal. Local, state and federal agencies; civic organizations; and financial institutions...

The Center for Responsible Lending, Consumer Federation of America, and Empire Justice Center submitted comments to the Federal Housing Finance Agency on a proposed rule for the 2012-2014 Enterprise Housing Goals. "It is critical that FHFA continue to focus on its responsibility of ensuring that the Enterprises serve the entire housing market." The Enterprises can do this while fostering a...

Lack of regulation led to the foreclosure crisis that has destabilized the housing market and mortgage lending: Federal regulators could have stepped in to curb abusive lending practices in the years leading up to the foreclosure crisis, but this failed to happen. Instead, the private label securitization system bypassed government oversight by bundling an increasing number of subprime and Alt-A...

Prepaid cards are an important new financial product that holds the promise of expanding access to modern electronic transactions to millions of consumers. However, prepaid cards lack consumer protections and some have features that expose consumers to unnecessary dangers. The most important step that the CFPB can take to ensure that prepaid cards fulfill their promise, and to prevent unfair...

Testimony of Kenneth W. Edwards Vice President of Federal Affairs, Center for Responsible Lending, before the House of Representatives Committee on Financial Services Subcommittee on Financial Institutions and Consumer Credit in regards to hearing on Examining Consumer Credit Access Concerns. The testimony emphasized three points: H.R. 6139 and similar legislation would circumvent the carefully contemplated supervisory, enforcement, and rulemaking authority...

Read the Executive Summary This report by Pew's Safe Small-Dollar Loans Research Project—the first in Pew's Payday Lending in America series—answers major questions about who borrowers are demographically; how people borrow; how much they spend; why they use payday loans; what other options they have; and whether state regulations reduce borrowing or simply drive borrowers online. Pew: Who Borrows, Where...

74% of Americans favor the CFPB Voters are nearly unanimous in their support for specific policies the CFPB has created A July 2012 poll demonstrates very broad bipartisan support for the Consumer Financial Protection Bureau (CFPB) and other reforms in the Dodd-Frank Wall Street Reform and Consumer Protection Act. This poll--taken at the two-year anniversary of Dodd-Frank--has similar results to...

Remarks by Bill Sermons, Research Director from the Center for Responsible Lending, before the Credit Reporting Field Hearing convened by the Consumer Financial Protection Bureau in Detroit, Michigan on July 16, 2012.

On July 3, the NC General Assembly adjourned until January 2013. In this Legislative Wrap-up for the two-year session, we have summarized (click on each bill to learn more): Bad bills that died HB 810: Raise rates and fees on installment loans HB 814: Weaken mortgage lending protections HB 654: Weaken protections against foreclosure rescue scams and real estate abuses...

CRL Senior Vice President Eric Stein emphasized the importance of defining "Qualified Mortgage" broadly to avoid shutting out creditworthy borrowers from the mortgage market. He recommended that QM include the use of specific "bright-line" standards so that lenders and borrowers are clear on which loans qualify as QMs. He also made the case for allowing borrowers to pursue legal action...

The Center for Responsible Lending, Consumer Federation of America and The Leadership Conference on Civil and Human Rights responded to the CFPB's request for comments on qualified mortgages. Much of the comment letter focuses on an appropriate "bright line" debt-to-income ratio standard for QMs. Setting a narrow debt-to-income ratio for QMs would unnecessarily exclude a large share of borrowers from...

CRL joined with CFA and NCLC to provide the CFPB (Consumer Financial Protection Bureau) with documentation of bank overdraft practices and their impact on consumers. The CFPB should stop banks from reordering transactions and should prohibit overdraft fees on debit card transactions, which can easily be declined at no cost.

Carve-Out Undermines New Federal Consumer Oversight Infrastructure At the root of HR 1909 and similar legislation is an effort by non-bank lenders to circumvent new federal oversight and undermine consumer protections recently provided under the Dodd-Frank Act. HR 1909 will allow non-bank lenders selling a broad range of predatory products, including payday loans and car-title loans, to be chartered and...

The Foreclosure Reduction Act (AB 278 & SB 900) is designed to provide Californians with better safeguards and fair treatment in the foreclosure process. The California Bankers Association and other industry groups recently released a flawed report purporting to show how the bill will extend the foreclosure process and have detrimental economic consequences. The proponents' claims are unsubstantiated and are...