Comment Letter

Fifteen consumer, student, civil rights, and legal aid groups co-signed a letter to Consumer Financial Protection Bureau Director Richard Cordray in response to the agency's Request for Information about the Student Safe Account Scorecard. The organizations supported the Scorecard and stated: Colleges and universities must begin to put the best interest of students first when negotiation with banks and prepaid card issuers The Student Safe Account Scorecard is a voluntary tool for schools to use in their bidding process with financial institutions The Scorecard would help schools select safe...

In this letter to Consumer Financial Protection Bureau Director Richard Cordray the Center for Responsible Lending and the National Consumer Law Center respond to the agency's Request for Information about the Student Safe Account Scorecard, which would guide colleges to select safe bank accounts if they enter into marketing partnerships with banks. In the letter, the two organizations support the Scorecard as a way to help protect students, and call for: An end to college-bank partnerships that threaten students with unfair marketing practices and harmful fees The elimination of revenue...

In this letter (2 pages), six consumer and civil rights groups ask Members of Congress to oppose H.R. 685, The Mortgage Choice Act of 2015. The groups argue that the bill would raise the cost of mortgages for millions of prospective homebuyers by allowing higher fees and creating a loophole in the landmark Dodd-Frank Wall Street Reform and Consumer Protection Act. The groups state: H.R. 685 would unnecessarily raise the cost of mortgages H.R. 685 would allow high-cost loans to qualify as QM loans by creating exceptions to the points and fees threshold; the exception would exclude fees paid to...

In response to a request for comment, CRL offered feedback to the Consumer Financial Protection Bureau about the agency's proposed rule addressing prepaid cards. The CFPB's proposed rule would expand consumer protections on prepaid cards in significant respects. The CRL comment focuses on credit products associated with prepaid cards – with a particular focus on overdraft fees. The CRL comment strongly urges the CFPB prohibit any overdraft charges on prepaid cards. CRL's comment supports that CFPB's proposal would apply stronger regulations to overdraft fees on prepaid cards than the wholly...

Major consumer groups have submitted comment today urging the Department of Defense to protect the men and women who serve the country by creating strong, new regulations implementing the Military Lending Act (MLA). The Center for Responsible Lending, Consumer Federation of America, Consumer Action, the National Association of Consumer Advocates, the National Consumer Law Center (on behalf of its low income clients), and U.S. PIRG joined together to urge the Defense Department to strengthen the MLA rule.

As the Consumer Financial Protection Bureau refines mortgage rules, CRL addresses how mortgage put-backs by GSEs should affect the Qualified Mortgage status of mortgage loans. CRL also support CFPB's rule that state servicing standards will not be preempted by Federal rules.

Should federally-insured credit unions push payday loans with triple-digit interest rates? CRL and the National Consumer Law Center (NCLC) say no, urging the National Credit Union Administration (NCUA) to stop its members from making these types of predatory loans. Most credit unions conduct responsible lending that does not include payday-type loans. However, NCLC has identified nine federal credit unions that offer short-term loans with triple-digit rates. These credit unions either make the loans directly or have an arrangement with a third party that uses the credit union's name and makes...