Comment Letter

This letter suggests improvements to the rule that would amend the Borrower Defense to Repayment provision of the Higher Education Act (HEA) in order to ensure that students and taxpayers will not have to bear the economic burdens that arise when higher learning institutions make misrepresentations and fail to provide an adequate education to students. CRL applauds the Department for...

The Center for Responsible Lending strongly supports allowing former ITT students access to the Guaranty Fund. Over the past few years, CRL has been engaged in research and policy regarding for-profit institutions of higher education. During the 2016 legislative session, the Center for Responsible Lending submitted written testimony in support of SB 427, An Act Concerning Higher Education – Institutions...

The undersigned Center for Responsible Lending (CRL) and National Consumer Law Center, on behalf of its low income clients (NCLC), write to comment on the update to the Uniform Interagency Consumer Compliance Rating System (CC Rating System) by highlighting three areas of particular concern: Overdraft practices Loans with a total cost of credit exceeding 36% annual percentage rate (APR) Bank...

The Financial CHOICE Act attacks the CFPB's structure and authority and would frustrate the CFPB's ability to fulfill its mission. Title III of the bill is aimed at obstructing the CFPB's ability to protect consumers from predatory financial products and practices. This title severely weakens the CFPB’s structure and authority in the following ways: Changes the structure of the CFPB...

CRL strongly supports the CFPB’s proposed rule to limit pre-dispute mandatory (forced) arbitration clauses in consumer finance contracts. Forced arbitration is a widespread issue affecting a plethora of financial products and services; it impacts the consumers CRL advocates for and implicates CRL’s mission to eliminate abusive financial practices. CRL applauds the CFPB for its efforts to restore consumers’ ability to...

In a Statement for the Record to the Hearing of the Senate Committee on Banking, Housing, and Urban Affairs: Assessing the Effects of Consumer Finance Regulations, CRL expresses its support for post-crisis lending rules that have made the financial system safer by eliminating abusive financial products, reining in reckless behavior, and encouraging more effective oversight.

CRL applauds FHFA for its recognition of the importance of the Duty to Serve mandate in the Housing and Economic Recovery Act of 2008 (HERA) and for putting forth a strong proposed rule. We strongly support much of what FHFA is proposing. The comments in this letter address numerous questions on which FHFA requests input, including general process, evaluation, and...

Cars are the most common nonfinancial asset held by American families, and for some families, their most significant asset. Cars have become a necessity for U.S households, with more than 85% of the U.S. workforce using an automobile to commute to work. Car ownership is no longer a luxury but is a prerequisite to economic opportunity. The need for a...

A letter from seventeen consumer and civil rights advocacy groups to investor and auto dealer, Warren Buffett, urging him to help end discriminatory auto lending practices in this country. In 2014, Mr. Buffett's Berkshire Hathaway purchased the largest privately-held auto dealership group in the nation, the Van Tuyl Group. This letter calls attention to the widely documented problem of "racially...

Unfair debt collection practices, particularly those of debt buyers, undermine individuals' financial security, especially among low-income households and households of color. When people are pursued or sued for debt they do not owe, these unfair collection attempts not only threaten the unnecessary extraction of money from individuals, but also hinder opportunities to build assets for the future. Towards this end...