Research & Policy

The following two comments oppose the National Credit Union Administration (NCUA or the Board)’s proposal to expand the activities in which credit union service organizations (CUSOs) are permitted to engage. This proposal will authorize predatory lending by credit unions, hampering household security at a time when greater security is badly needed. It will also increase racial discrimination, as families of...

On April 28, 2021, Lisa Stifler testified in front of the Committee on Banking, Housing, and Urban Affairs during a hearing entitled, "The Reemergence of Rent-a-Bank?" Her written testimony as well as her oral remarks are available for download. Watch Lisa Stifler's opening remarks and the entire hearing:

The Office of the Comptroller of the Currency’s (OCC) “fake lender” rule is an existential threat to state interest rate limits that protect consumers from predatory lending. Since the American Revolution, states have limited interest rates to stop predatory lending. Forty-five states and the District of Columbia (DC) have interest rate caps on at least some installment loans, depending on...

Millions of homeowners across the country are having difficulty affording their monthly mortgage payments because of the COVID-19 pandemic. The most vulnerable group of borrowers is concentrated within the Federal Housing Administration (FHA) program, with over 900,000 borrowers who are more than 90 days delinquent. While the CARES Act provided homeowners with access to a mortgage forbearance and while subsequent...

Saving for a mortgage down payment is a significant barrier to homeownership that particularly hits communities of color. We calculate how long it would take for a typical renter household to save for a mortgage down payment and closing costs for a median-priced house (“Years to Save”) and further disaggregate these calculations by race/ethnicity, household type, location, and occupation. We...

The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Request for Input on Climate and Natural Disaster Risk Management at the Regulated Entities. CRL is a nonprofit, non-partisan research and policy organization dedicated to protecting homeownership and family wealth by working to eliminate abusive...

The private bail bonds industry is woefully underregulated. Unlawful consumer credit arrangements and debt–collection practices abound, yet no government body is charged with addressing these aspects of bail bonds contracts. DFPI has the authority and the expertise to provide much-needed regulation in this industry and doing so would align with its mission. For the good of bail bonds consumers too...

The coalition of signatories to the letter consists of 325 groups, including civil rights, community, consumer, faith, housing, labor, legal services, senior rights, small business, student lending, and veterans organizations. The letter states that “[t]he rule replaces the longstanding ‘true lender’ anti-evasion doctrine with a ‘fake lender’ rule that allows lenders charging rates of 179% or higher to evade state...

Over 60 community development, civil rights, and small business groups are urging swift extension of the Paycheck Protection Program by Congress. The extension should not preclude any necessary SBA rulemaking authority. The letter also flags the continued need to make the recent change for Schedule C filers retroactive.

Key points from the poll results include: Download a one-page summary of the results. As a result of the COVID 19 crisis, payments have been paused for federal student loan borrowers nationwide until at least September 2021 Almost one in three 28 Minnesota borrowers are not confident that they will be able to resume payments on their student loans when...

“Oportun,” is almost a translation of the Spanish word for “opportunity,” but is a few letters shy of the full word: oportunidad. Unfortunately, Oportun’s practices leave people questioning just how much financial opportunity consumers receive as a result of using these products. “Partner with us today to build a better tomorrow.” “We’re committed to our community.” These messages and other...

On March 16, 2021, Nikitra Bailey testified in front of the Committee on Banking, Housing, and Urban Affairs during a hearing entitled, "Home = Life: The State of Housing in America." Her written testimony as well as her oral remarks are available for download. Watch Nikitra Bailey's opening remarks and the entire hearing:

This set of comments will focus on earned wage access programs and other newer types of payday advance programs. NCLC and CRL have also joined a broader set of comments submitted by the California Economic Justice Coalition on a broader range of issues and a second set in conjunction with the Student Borrower Protection Center on income share agreements. These...

On September 25, 2020, Governor Newsom signed AB 1864 (Chapter 157, Statutes of 2020), establishing the California Consumer Financial Protection Law (“CCFPL”) under Division 24 of the Financial Code. The undersigned consumer advocates are encouraged to see that the Department of Financial Protection and Innovation (“DFPI” or the “Department”) is seeking input from stakeholders in developing regulations to implement the...

On March 11, 2021, Ashley Harrington testified before the House Financial Services Committee. Her written testimony as well as her oral remarks are available for download. Watch her opening remarks and the entire hearing:

On March 10, 2021, Nikitra Bailey testified before the House Financial Services Committee. Her written testimony as well as her oral remarks are available for download. Watch her opening remarks and the entire hearing:

From the comment: The Center for Responsible Lending (CRL) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Resolution Planning proposed rule. FHFA seeks comment on a proposal that would require Fannie Mae and Freddie Mac (GSEs) to develop plans to facilitate their rapid and orderly resolution in the event FHFA is appointed receiver pursuant to 12...

Our broad coalition of consumer and business organizations thanks you for the opportunity to comment regarding how the DFPI can best implement AB 1864 (Limón), the California Consumer Financial Protection Law (CCFPL). The CCFPL is an important and significant step forward for California and offers the promise of a bold consumer-facing department that can be at the forefront of consumer...

From the amicus brief: Unpaid court debt balloons over time as fines and the costs of collection accrue; low-income people risk wage garnishment, asset forfeiture, loss of credit, and even incarceration as collateral consequences of their continued entanglement with the criminal justice system. These burdens fall most heavily on people of color, who are arrested and placed on probation at...

In the letter from 138 undersigned consumer, civil rights, community, housing, labor, small business, and other public interest groups: Commissioner Chopra is exactly the type of leader we need to serve as the next CFPB director. His commitment to consumer protection, effectiveness at using the tools of government to serve the public interest, and willingness to challenge powerful corporate interests...

The Center for Responsible Lending (CRL)1 appreciates the opportunity to comment on the Affordable Housing Goals Advance Notice of Proposed Rulemaking. In exchange for government support, Fannie Mae and Freddie Mac (GSEs) have an explicit public interest mission. This mission is foundational and part of their charters – the GSEs’ very reason for existing.2 The mission includes promoting access to...

Even before COVID-19, student loan borrowers struggled under the weight of more than $1.6 trillion in debt. One in four borrowers was in default or serious delinquency, and many worried about their ability to make student loan payments while covering other basic needs. Because of decades of structural inequities and discrimination, student loans have burdened Black and Latino borrowers more...

The Center for Responsible Lending and Self-Help filed a joint comment to the Federal Reserve Board on its Advance Notice of Proposed Rulemaking on regulations that implement the Community Reinvestment Act (CRA). Read the full comment.

From the comment letter: NCUA’s proposal, which would permit federal credit unions (FCUs) to keep members’ negative account balances open for longer than the current limit of 45 days, offers no evidence that it will achieve its stated goal -- to provide relief to FCU members. At the same time, the proposal fails to consider the significant risks it poses...

100 organizations supporting African American, Latino and immigrant-owned businesses across the country, joined in this letter to request that changes be immediately made to the Paycheck Protection Program (PPP) to increase meaningful access for sole proprietors, independent contractors, and self-employed individuals. While the Economic Aid Act addressed many of the impediments to access for business owners of color, barriers remain...