Comment Letter

Today, the Center for Responsible Lending (CRL) filed a public comment on urgently needed rules proposed by the California Department of Business Oversight (DBO) that would require payday lenders to follow California law by prohibiting the use of electronic transfers and debit cards in payday transactions. The rules would also create a new real-time electronic database to enforce existing law...

Fifteen student, consumer, civil rights, and labor groups co-signed a letter (4 pages) in support of the Consumer Financial Protection Bureau's proposed rule on prepaid cards. The groups suggest that the new rule would support similar actions by the Department of Education, aimed to protect students using prepaid cards. The groups state: College students are a key segment of the...

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...

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...

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...

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...

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...

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...