Research & Policy

Many FHA borrowers took advantage of record-low interest rates during the COVI9-19 pandemic and refinanced their mortgage. However, as of November 2021, there were over 4 million FHA borrowers who could realize a substantial reduction in their monthly payments by refinancing but had not done so. The average borrower in this cohort would save $229 per month ($2,750 per year)...

Two vital elements of social and economic mobility are to increase the homeownership rate by enabling more non-homeowners to become first-time homebuyers and reduce the racial disparities in homeownership rates caused in large part by deliberate discriminatory policies and practices. The Government Sponsored Enterprises (GSEs) have the ability to improve both through their affordable housing goals and lending programs. The...

The exploding market of Buy Now Pay Later (BNPL) credit demands the same level of oversight that we give to credit cards. BNPL can help some borrowers spread out their payments, but entails real risks and costs, which is not clear in advertisements highlighting interest-free payments and “no impact” on credit scores. Regulation is necessary to protect consumers from hidden...

A broad coalition of bank and credit union associations and consumer organizations submitted a letter to the U.S. House Committee on Financial Services urging passage of the bipartisan Close the ILC Loophole Act. The bill would help prevent more companies from running what is essentially a bank without the necessary regulatory oversight.

The undersigned civil rights organizations do not believe the mandatory July 1 compliance date extension for the General QM Final Rule until October 1, 2022 is necessary since the new General QM definition and the Patch overlap so thoroughly. Please download the letter to continue reading.

“Income-share agreements,” or ISAs, fund a portion of educational costs in exchange for a percentage of a student’s earnings over time. Many ISA providers continue to argue that their products are not loans even though they lend money and subsequently require repayment, employing an old and predatory tactic that loan providers use to evade consumer protection guardrails. In fact, ISAs...

The group letter begins: The undersigned 77 consumer, housing, civil rights, legal services, faith, community, small business, student borrower, and public interest organizations appreciate the opportunity to comment on the CFPB’s inquiry into Buy Now, Pay Later (BNPL) credit products that are proliferating across market areas. We welcome the CFPB’s recent inquiry into Affirm, Afterpay, Klarna, PayPal, and Zip, however...

In response to the Request for Comments issued by the Consumer Financial Protection Bureau, the Center for Responsible Lending, the Consumer Federation of America, and the National Consumer Law Center (on behalf of its low-income clients) offer joint recommendations for further guidance and monitoring of the growing Buy-Now-Pay-Later market overall, which are specific to the "pay-in-four" model. Our comment covers...

On March 21, 2022, CRL submitted written testimony to the U.S. House of Representatives Committee on Small Business Subcommittee on Oversight, Investigations, and Regulations for the hearing, “ An Empirical Review of the Paycheck Protection Program.”

Payday lenders often describe the cost of their loans in terms of fees or simple interest rates. Responsible lenders readily disclose the APR on their loans, aligned with the Truth in Lending Act (TILA). They are not afraid to let their customers compare the costs of their loans to other loans in the market. Tellingly, payday lenders often object to...

Debt collectors, including debt buyers, have weaponized the courts and frequently sue the wrong consumer for the wrong amount. Armed with a judgment, they use wage garnishment orders and bank account levies to seize money from families who are the least able to afford it. Research shows that nearly half of all Americans do not have enough savings to cover...

The Center for Responsible Lending, Legal Aid of North Carolina, North Carolina Justice Center, National Association of Consumer Advocates, Charlotte Center for Legal Advocacy, Financial Protection Law Center and Pisgah Legal Services partnered to filed this amicus brief in the North Carolina Supreme Court in Townes v. Portfolio Recovery Associates (PRA). Townes v. PRA is principally about the interpretation of...

145 organizations sent a letter to the “Big Three” credit bureaus (Equifax, Experian, and Transunion) and to the Consumer Data Industry Association (CDIA), the trade association that represents them, urging them to take needed actions to correct credit report problems for transgender and nonbinary consumers.

CRL and more than 50 community development, civil rights and small business groups, including National Urban League, National Association for Latino Community Asset Builders, UnidosUS and National Coalition for Asian Pacific American Community Development are urging SBA and Congress to fix the Paycheck Protection Program’s current forgiveness rules so that microbusinesses can receive full forgiveness of their PPP loans. Urgent...

New polling data shows that Rhode Island voters across all political parties are broadly supportive of consumer protections to lower the maximum annual interest rate for payday loans in the state.

The “90/10 Rule” is meant to ensure that for-profit schools are, in fact, competitive in the marketplace and are not relying only on taxpayers to survive. In other words, the rule is based on the principle that a viable educational program should be funded in part by students or employers who are willing to pay cash to invest in career...

Download the letter to Secretary Miguel Cardona from 104 organizations representing students, student loan borrowers, teachers, workers, civil rights, veterans, people of faith, and consumers urging him to deliver on the promise of income-driven repayment (IDR) programs for federal student loan borrowers through the creation of an IDR restoration project, or an IDR waiver.

With a new chairman taking the helm of the Federal Deposit Insurance Corporation (FDIC), the Center for Responsible Lending joined with more than a dozen other organizations in calling for the FDIC to "stop permitting its supervised institutions to front for predatory lenders evading state interest rate limits."

Oportun is a California-based financial services provider that is rapidly expanding its reach. In some states, Oportun has announced its loans will be originated by MetaBank, indicating it is employing the “rent-a-bank” scheme, wherein lenders pay a bank with a national charter that is willing to pose as the lender so they can avoid having to comply with state consumer...

In a precedent-setting ruling, the California Court of Appeals at the end of 2021 handed down a decision affirming a broad preliminary injunction against a bail bond company called Bad Boys Bail Bonds. The court prohibited the company from collecting on $38 million in debt from cosigners who borrowed money to gain pre-trial release for their loved ones. The order...

Many of the problems that led to the failure of the Public Service Loan Forgiveness (PSLF) program are IDR problems in disguise—such as borrowers being steered into the wrong repayment plan and Family Federal Education Loan (FFEL) servicers failing to tell borrowers of consolidation options. These problems will not be corrected by a solution that only addresses the PSLF program.

The Center for Responsible Lending (CRL), the National Association of Latino Community Asset Builders (NALCAB), and the National Coalition for Asian Pacific American Community Development (National CAPCACD), along with eleven undersigned public interest groups submitted comments to the Consumer Financial Protection Bureau in regards to its proposed rule to implement Section 1071 of the Dodd-Frank Wall Street Reform and Protection...

The National Consumer Law Center, on behalf of its low-income clients, the Center for Responsible Lending, and the Consumer Federation of California submitted comments to the Department of Financial Protection and Innovation’s (DFPI) proposed regulation governing the registration and data reporting requirements for certain industries. These comments focused on the proposed registration of providers of wage-based advance providers. In these...

Letter to the CFPB from 79 consumer, housing, civil rights, legal services, faith, community, small business, and financial organizations groups regarding supervision and enforcement of fintech products and fee models that threaten to evade credit, consumer protection, and fair lending laws.

In a letter to California’s Department of Financial Protection and Innovation (DFPI), the Student Borrower Protection Center, the Center for Responsible Lending, the Consumer Federation of California, Consumer Reports, the Student Debt Crisis Center, the National Consumer Law Center, NextGen Policy, and Young Invincibles commented on proposed rules for education financing products in California. The letter notes that the DFPI’s...