Comments in Response to National Credit Union Administration Proposal to Expand its Payday Alternative Loan Program

We thank NCUA for its efforts to protect credit union members from payday loans. In recent years, the number of federal credit unions (FCUs) we are aware of engaging in payday lending, either directly or indirectly through credit union service organizations (CUSOs), has decreased to a single FCU. And through both its regular rules and its PAL program, NCUA has...

120 Consumer, Civil Rights, Community Groups Oppose HR 4439 and Sham Rent-a-Bank Payday Lending

Committee on Financial Services U.S. House of Representatives Washington, DC 20515 Re: HR 4439 (Hollingsworth), Sham Lender Bill – Oppose Dear Representative, The 120 undersigned consumer, civil rights, labor, community and legal services organizations strongly oppose HR 4439 (Hollingsworth), the so-called Modernizing Credit Opportunities Act. The bill would allow payday lenders to use the fine print of loan terms and...

CRL to Secretary DeVos: Work with - Not Against - Law Enforcement to End Student Loan Abuses

In response to the Education Department’s stated interests to end an 18-year old departmental practice of sharing information with law enforcement officials, the Center for Responsible Lending recently wrote comments urging Secretary Betsy DeVos to continue the productive and long-standing exchanges. Citing recent collaborations that together returned or forgave more than $36 million to harmed consumers in just four states...

Comments on Priorities for the Reauthorization of the Higher Education Act (HEA)

Any proposal should hold to the spirit of the original HEA which sought to open the doors of higher education to all. This proposition connotes meaningful access and opportunity to quality higher education programs, not simply the creation of more options or the provision of unduly burdensome loans. Despite this goal, our current system is at risk of curtailing the...

Comment to the CFPB on Request for Information on Payday Loans, Vehicle Title Loans, Installment Loans and Open-end Lines of Credit

Lenders can and do make non-covered loans without regard to the borrower’s ability to repay as scheduled, and doing so can be highly profitable. In particular, high-cost loans provide a significant disincentive against lending based on ability to repay, even absent a coercive repayment mechanism or security. When rates are high, lenders can profit despite significant defaults and can even...

Comments on the Qualified-Mortgage Rule Under the Truth in Lending Act (Regulation Z)

These comments respond to the Consumer Financial Protection Bureau’s proposed amendments to the qualified-mortgage (QM) rule as it relates to 1) the importance of the QM rule, 2) why the constrained lending environment is due to factors other than QM, and 3) why they should be addressed rather than weakening QM, 4) our analysis of CFPB’s proposed evaluation, and 5)...

Fannie Mae and Freddie Mac's Proposed Underserved Markets Plans

The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, NAACP, National Coalition for Asian Pacific American Community Development, National Fair Housing Alliance, and National Urban League file this comment in response to Fannie Mae's and Freddie Mac's (the Enterprises) proposed Underserved Markets Plans. (pdf) Thank you for the opportunity to provide input on the Enterprises’ plans...

Comments on Duty to Serve Evaluation Guidance

The Center for Responsible Lending (CRL) filed this comment in response to FHFA's proposed evaluation guidance for the Duty to Serve Rule. The evaluation guidance is the method for FHFA to assess Fannie Mae and Freddie Mac's (the Enterprises) Duty to Serve Underserved Markets Plans. The strength and clarity of the evaluation guidance will greatly inform the Enterprises' plans. A...

Evaluating Charter Applications from Financial Technology Companies

Despite significant concerns raised by a number of interested parties—including hundreds of advocacy groups, state regulators, and a bipartisan group of Members of Congress—the OCC is moving forward with its fintech charter proposal. This comment letter asserts that the OCC does not have the legal authority to charter non-depositories, that a national bank charter for non-depository fintech institutions will facilitate...

Comment on FDIC Seeking Comment on Proposed Guidance for Third-Party Lending

The Federal Deposit Insurance Corporation's (FDIC) proposed guidance provides a framework that will require banks to place more stringent requirements on the institutions that they conduct business with. However, as written, the proposed guidance will still enable consumer harm and allow FDIC-supervised institutions to engage in risky relationships with third parties via rent-a-bank lending. We are deeply concerned about the...