QRM Comments: Mortgage Market of the Future can Produce Sensible Loans without High Down Payments

The mortgage market of the future can drive economic growth without shutting out responsible home buyers. Here is an overview of CRL's recommendations to regulators: The Agencies should delay finalizing the QRM rule until after the final QM rule has beenissued. The QRM final rule should be harmonized with the QM final rule to facilitate compliance. QRM loans should meet...

Comments to the Consumer Financial Protection Bureau and the Federal Reserve Board re: Regulation Z: Proposed Rule on Ability to Pay and Qualified Mortgage

In its first formal comment to the CFPB, the Center for Responsible Lending supports new Dodd-Frank mortgage reforms and urges the CFPB to ensure that lenders have appropriate consequences if they fail to abide by the rules.

Comments on NCUA's Notice of Proposed Rulemaking on Short-term, Small Amount Loans

SUMMARY We commend NCUA for its efforts to encourage federal credit unions (FCUs) to offer responsible small loan products. However, we encourage NCUA to think of this program in the context of two realities: 1) short-term loan products, whether they are called "payday loans" or are offered through a credit union, are likely to trap already vulnerable customers in costly...

Joint Letter to Regulators on Elements of "Qualified Residential Mortgages"

In this letter to federal regulators, CRL and other national civil rights, labor and consumer organizations share their views on the regulation of securitizers of residential mortgage loans - specifically "qualified residential mortgages" or QRMs. The two points made by the letter: 1. Securitized loans should meet basic servicing standards to prevent unnecessary foreclosures 2. QRM standards should not include...

Comments to the Federal Reserve Board on Proposed Regulations Under the Truth in Lending Act [Regulation Z; Docket No. R-1390]

The National Consumer Law Center ("NCLC") respectfully submits the following comments on behalf of its low income clients, as well as Americans for Financial Reform, California Reinvestment Coalition, the Center for Responsible Lending, Consumer Action, Consumers Union, National Association of Consumer Advocates, National Community Reinvestment Coalition, National Fair Housing Alliance and the Neighborhood Economic Development Advocacy Project, regarding the Federal...

Joint Letter in Support of FDIC Overdraft Proposals September 2010

Download the joint letter >> CRL and a cross-section of civil rights, labor, consumer, housing, community, business, and sustainable and responsible investor groups sent a joint letter to the FDIC expressing support for bringing attention to abusive overdraft practices. The groups support the agency's common-sense recommendations for actions banks should take to treat their customers more fairly while offering recommendations...

Comment Letter on FDIC's Proposed Overdraft Guidance

CRL and other consumer advocates filed a comment letter with the FDIC supporting most aspects of the agency's proposed guidance on overdraft. The groups also made recommendations on how the agency could go even further in protecting consumers from excessive overdraft fees. Here is the summary of key recommendations from CRL, Consumer Federation of America, National Consumer Law Center, Consumer...