Comment Letter

Amid growing concern about corporate consolidation, the Center for Responsible Lending (CRL) and Americans for Financial Reform Education Fund are leading a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank. Their comment letter points to several reasons why regulators should...

The Center for Responsible Lending and Center for Community Self-Help applaud the effort of the Agencies to update and modernize the CRA regulations given the massive changes that have taken place in the financial services industry in the more than 25 years since the regulations were last amended. Likewise, we support the overall thrust of the Agencies’ proposal, which provides...

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. Thank you for the opportunity to provide input on the Enterprises’ plans. The...

The Center for Responsible Lending and the undersigned consumer, civil rights, and community organizations would like to thank you for the opportunity to submit comments on the Federal Housing Finance Agency’s (FHFA) proposed rule setting the 2018-2020 Affordable Housing Goals for Fannie Mae and Freddie Mac (“Enterprises”). We appreciate FHFA’s efforts to improve strategies to ensure those from lower wealth...

Deregulatory measures are not the antidote to the affordable housing crisis in our nation. The government must provide the necessary investments to combat the crisis and ensure that potential regulatory changes enhance equity, not detract from it. HUD and the White House Council must not use the RFI process to undermine important public interest protections, such as civil rights, labor...

NALCAB, the National Association for Latino Community Asset Builders, The National Coalition for Asian Pacific American Community Development (CAPACD), and the Center for Responsible Lending (CRL) write in response to the invitation for public comments regarding changes made to the Community Advantage Pilot Program (CA) noticed in the Federal Register on April 29th, 2022. Access to capital is one of...

CRL urges FHFA to provide for a streamlined approval process for the GSEs to submit new activities that do not rise to the level of a new product. Otherwise, given the proposed rule’s extraordinarily broad definition of a new activity, the GSEs will be stymied from pursuing new endeavors by excessive red tape and overly burdensome documentation requirements. A streamlined...

From the introduction to the comment: Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low income clients), Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of Transportation Alliance Bank (dba TAB Bank). TAB...

The Center for Responsible Lending (CRL), along with Americans for Financial Reform (AFR), Consumer Federation of America (CFA), the National Community Reinvestment Coalition (NCRC), and National Consumer Law Center (NCLC) (on behalf of its low-income clients) submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to their call for public input on how to save Americans...

In response to the Request for Comments issued by the Consumer Financial Protection Bureau, the Center for Responsible Lending, the Consumer Federation of America, and the National Consumer Law Center (on behalf of its low-income clients) offer joint recommendations for further guidance and monitoring of the growing Buy-Now-Pay-Later market overall, which are specific to the "pay-in-four" model. Our comment covers...