Research & Policy

From the introduction to the comment to the Federal Housing Finance Agency: On behalf of the undersigned consumer, civil rights, and housing organizations, we would like to thank you for the opportunity to comment on the affordable housing goals for Fannie Mae and Freddie Mac (the GSEs). In exchange for government support, the GSEs have an explicit public interest mission...

Ten years after passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, with the country again facing an economic crisis, new polling data from Lake Research Partners, commissioned by the Center for Responsible Lending and Americans for Financial Reform shows that voters across all political parties are broadly and intensely supportive of strong consumer financial protections and of...

Prior to the COVID-19 crisis, court fines and fees, and other monetary sanctions overly burdened young people and adults involved in the criminal legal system with debt from pre-trial through post-release and beyond. A few months into the crisis, we are seeing that Black and Brown communities are disproportionately facing economic challenges. This is reflected in national unemployment data, where...

From the comment to the CDFI Fund on the Small Dollar Loan Program: The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), NAACP, Americans for Financial Reform Education Fund, Consumer Federation of America, and Public Citizen appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan Program (SDLP)...

From the full comment: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB’s) qualified mortgage (QM) proposed rule. Given CFPB’s decision to end the GSE patch, we believe that a price-based approach is an appropriate and effective method to determine QM status. However, additional safeguards are necessary to ensure that the final rule effectively protects...

In a September 3 letter to Acting Comptroller of the Currency, Brian Brooks, the Coalition for Responsible Lending wrote: We oppose the OCC’s proposed rule to permit lenders to use the rent-a-bank model to avoid North Carolina’s rigorously enforced interest rate cap. The OCC’s proposed rule will let predatory lenders off the hook for charging interest and fees in excess...

From the comment to the Office of the Comptroller of the Currency, Notice of Proposed Rulemaking, "National Banks and Federal Savings Associations as Lenders": We, the consumer and civil rights groups named above, write to strongly oppose the Office of the Comptroller of the Currency’s (OCC) proposed rule preempting the authority of states and courts to look beyond contrivances to...

In a September 3 letter to Acting Comptroller of the Currency, Brian Brooks, the Californians for Economic Justice Coalition wrote: California has strong interest rate caps on installment loans intended to protect our residents from predatory loans. Understanding that products like payday loans, car-title loans, and high-cost installment loans at sky high interest rates are merely debt traps for borrowers...

More than 100 community, consumer, civil rights, and faith organizations wrote to vigorously oppose the OCC’s proposed rule to gut the longstanding "true lender" anti-evasion doctrine. The proposed rule would trample state interest rate limits and unleash predatory lending in all 50 states, further exacerbating the economic impacts already experienced by COVID-19.

Introduction and Executive Summary Thank you for the opportunity to comment on the Federal Housing Finance Agency’s (FHFA’s) re-proposed rule on capital requirements for Fannie Mae and Freddie Mac (the governmentsponsored enterprises, or GSEs). In our view, the proposed rule erroneously treats the GSEs as banks and therefore requires banklike capital. This leads to gratuitously high capital levels that run...

The Consumer Financial Protection Bureau (CFPB), under Director Kathy Kraninger, gutted a 2017 CFPB rule aimed at stopping the debt trap caused by payday and car title loans. This action will have a harmful impact on American consumers and their families, including a disproportionate number of people of color. Download the one-pager to learn more.

For years, predatory lenders have sought ways to avoid state interest rate limits. One scheme has been the “rent-a-bank” scheme. Under this scheme, a non-bank lender finds a bank willing to be the nominal originator of the non-bank lender’s high-cost loan, because banks are generally exempted from complying with state interest rate laws. State regulators, state attorneys general, and consumers...

The undersigned consumer and civil rights organizations appreciate the opportunity to submit comments on the Consumer Financial Protection Bureau’s (CFPB or Bureau) 2020 Supplemental Notice of Proposed Rulemaking (supplemental proposed rule) on debt collection. As organizations dedicated to eliminating abusive financial practices – particularly focused on communities of color and low- to moderate-income consumers – we are deeply concerned about...

From the amicus brief: This case concerns the authority of the Office of the Comptroller of the Currency (OCC) to extend the privileges of national banks to entities that do not accept deposits and are not banks in any traditional or legal sense. The foremost reason why non-banks will seek out a “special purpose national bank” is to take advantage...

We support the CFPB’s decision to conduct additional testing of the validation notice it has proposed and agree that such research is a necessary part of the Bureau’s debt collection rulemaking. As discussed below, we believe that the utility of the research will depend upon: the criteria used to select individuals to participate in the research; and the scope of...

Download the sign-on letter from the 101 undersigned community, civil rights, consumer, and student advocacy organizations insisting on student debt cancellation for all borrowers during negotiations over the next coronavirus relief package.

Download the full letter from Wells Fargo's Michael DeVito, EVP of Head of Home Lending, to the U.S. Department of Housing and Urban Development regarding the Fair Housing Act Disparate Impact Rule.

Industrial loan companies (ILCs) or industrial banks (IBs) (together, “ ILCs”) typically enjoy the privileges of traditional banks but pose two significant risk factors unique to ILCs: They are not subject to the Federal Reserve’s supervision, which occurs at the consolidated level (i.e., the ILC’s parent company, the ILC, and their affiliates); and They permit the intermingling of commercial and...

The Center for Responsible Lending (CRL) joined with a coalition of civil rights, community, consumer, and faith organizations in two public comment letters warning the Federal Deposit Insurance Corporation (FDIC) that its proposed rule for chartering additional underregulated Industrial Loan Companies (ILCs) would expand predatory, high-interest lending. The plan would grant the predominantly online non-bank companies that are approved for...

On May 20, 2020, the Office of the Comptroller of the Currency (OCC) acted alone in issuing a structurally flawed final rule on the Community Reinvestment Act (CRA) that weakens the CRA and will harm low- and moderate-income (LMI) communities and communities of color. Rather than postpone rulemaking to focus on the devastating economic crisis caused by the COVID-19 health...

On June 17, 2020, Ashley Harrington testified before the House Small Business Committee. This written testimony focuses on: Presenting an overview of the disproportionate economic impacts of the COVID-19 health crisis. Discussing issues with the structure and implementation of the PPP and how they served to limit access for the smallest businesses and businesses owned by people of color. Highlighting...

The Center for Responsible Lending (CRL), Self-Help Federal Credit Union, Self-Help Credit Union, and the National Consumer Law Center (on behalf of its low income clients) (NCLC) write to share concerns with the Interim Final Rule on Overdraft Policy that was considered and tabled at NCUA’s May Board meeting. Unfortunately, the proposal fails to offer members relief from overdraft fees...

A review of 2019 data shows that big banks continue to collect over $11 billion in overdraft related fees each year. Banks engage in a number of abusive practices that combine to drain massive sums from their customers’ checking accounts. The large majority of these fees are shouldered by banks’ most vulnerable customers, often driving them out of the banking...

This comment includes examples that are intended to be illustrative of the kinds of issues confronting low-to-middle-income households and communities of color attempting to navigate the consumer finance system.

CRL joined with more than 400 organizations to call on Congress to pass meaningful police reform legislation: Abusive police practices coupled with devastating state-sanctioned violence have exacted systemic brutality and fatality upon Black people since our nation’s founding. The current protests across our country are not new. They are in response to a long cycle of lawlessness against Black people...