Comment Letter

From the coalition letter to Michael J. Hsu, acting comptroller of the currency, Office of the Comptroller of the Currency: We the undersigned community, consumer, and civil rights organizations write to express serious concerns about Oportun’s application to the Office of the Comptroller of the Currency (OCC) for a national bank charter. Exactly one year ago, Oportun made headlines for...

The undersigned fair housing, affordable housing and civil rights organizations write to you in response to the proposed Interim Final Rule entitled “Restoring Affirmatively Furthering Fair Housing Definitions and Certifications.” We are heartened to see HUD moving toward restoring a meaningful Affirmatively Furthering Fair Housing (AFFH) rule to better implement the letter and spirit of the Fair Housing Act (“the...

The Center for Responsible Lending (CRL) and the National Community Stabilization Trust (NCST) appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s proposed rule on Protections for Borrowers Affected by the COVID-19 Emergency Under the Real Estate Settlement Procedures Act (RESPA), Regulation X. Our organizations strongly support the Bureau’s goals of preventing avoidable foreclosures and maximizing home retention...

The following two comments oppose the National Credit Union Administration (NCUA or the Board)’s proposal to expand the activities in which credit union service organizations (CUSOs) are permitted to engage. This proposal will authorize predatory lending by credit unions, hampering household security at a time when greater security is badly needed. It will also increase racial discrimination, as families of...

The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Request for Input on Climate and Natural Disaster Risk Management at the Regulated Entities. CRL is a nonprofit, non-partisan research and policy organization dedicated to protecting homeownership and family wealth by working to eliminate abusive...

The private bail bonds industry is woefully underregulated. Unlawful consumer credit arrangements and debt–collection practices abound, yet no government body is charged with addressing these aspects of bail bonds contracts. DFPI has the authority and the expertise to provide much-needed regulation in this industry and doing so would align with its mission. For the good of bail bonds consumers too...

This set of comments will focus on earned wage access programs and other newer types of payday advance programs. NCLC and CRL have also joined a broader set of comments submitted by the California Economic Justice Coalition on a broader range of issues and a second set in conjunction with the Student Borrower Protection Center on income share agreements. These...

On September 25, 2020, Governor Newsom signed AB 1864 (Chapter 157, Statutes of 2020), establishing the California Consumer Financial Protection Law (“CCFPL”) under Division 24 of the Financial Code. The undersigned consumer advocates are encouraged to see that the Department of Financial Protection and Innovation (“DFPI” or the “Department”) is seeking input from stakeholders in developing regulations to implement the...

Our broad coalition of consumer and business organizations thanks you for the opportunity to comment regarding how the DFPI can best implement AB 1864 (Limón), the California Consumer Financial Protection Law (CCFPL). The CCFPL is an important and significant step forward for California and offers the promise of a bold consumer-facing department that can be at the forefront of consumer...

From the comment: The Center for Responsible Lending (CRL) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Resolution Planning proposed rule. FHFA seeks comment on a proposal that would require Fannie Mae and Freddie Mac (GSEs) to develop plans to facilitate their rapid and orderly resolution in the event FHFA is appointed receiver pursuant to 12...