Comment on the ED’s Proposed Distance Education Rule: As More Programs Move Online, Do Not Weaken Student Protections

From the full comment letter: As more borrowers than ever migrate to online platforms, the Department’s role in ensuring program integrity is even more vital. The consensus language in the NPRM represents the best compromise between industry, innovators, and borrowers. If it is changed at all, it should be strengthened, not weakened. The final rule should include the consensus definitions...

Strong Opposition to the OCC and FDIC’s Proposed Community Reinvestment Act (CRA) Regulations

From the full comment letter: The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) strongly oppose the OCC and FDIC’s proposed Community Reinvestment Act (CRA) regulations.... The most troubling outcome of theproposed rule is that it would unwittingly sanction redlining. The proposal relies on an overly simplistic evaluation measurethat focuses on the total dollar value of...

Deposit Insurance Applications by Industrial Banks and Industrial Loan Companies

From the letter: We believe such a rulemaking is necessary to provide much-needed clarity to this thus-far opaque part of the U.S. financial system – that is, the manner in which parent companies and affiliates of ILCs are subject to any kind of federal regulatory or supervisory oversight. By contrast, the federal statutory, regulatory and supervisory framework for parent companies...

Comments on Proposed Rule Setting the 2018-2020 Affordable Housing Goals for Fannie Mae and Freddie Mac

First, we note that the affordable housing goals are part of the FHFA’s clearly laid out mission to reach underserved communities and that increasing access to mortgage credit in these communities is essential to the housing recovery. Second, we recommend that the FHFA maintain the two-part test, and strongly urge that the FHFA set a higher benchmark standard and require...

Letter to the FDIC Opposing the Evisceration of State Interest Rate Limits Around the Country

The undersigned community, consumer, civil rights, faith and small business organizations write to strongly oppose the FDIC’s proposed rule on “federal interest rates,” which threatens to eviscerate state interest rate limits around the country and encourage the spread of predatory lending. Download the letter to continue reading. (PDF)

Comment to the OCC in Strong Support for Effective Enforcement of the Community Reinvestment Act

These comments are submitted on behalf of the National Fair Housing Alliance (NFHA) and the Center for Responsible Lending (CRL) to express our organization’s strong support for effective enforcement of the Community Reinvestment Act, and our concern about the approach proposed by the OCC in the above-referenced Federal Register notice, dated September 5, 2018, entitled “Reforming the Community Reinvestment Act...

Comment Opposing the FDIC’s Proposed Rule That Would Allow Predatory Non-bank Lenders to Route Their Loans Through Banks

We, the consumer and civil rights groups named above, write to strongly oppose the Federal Deposit Insurance Corporation (FDIC)’s proposed rule on Federal Interest Rate Authority (proposal or proposed rule). The proposed rule would allow predatory non-bank lenders to route their loans through banks to evade state interest rate caps. The proposal is outside the FDIC’s statutory authority; it is...

Community, Consumer, Civil Rights, and Faith Groups Strongly Oppose OCC's Proposed Rule on State Interest Rate Limits

From the letter: Interest rate limits are the single most effective tool states have to protect their residents from predatory loans. Predatory loans include payday and car title loans that often carry annual interest rates as high as 300% or more. Predatory loans also include high-cost installment loans and lines of credit with rates approaching and well exceeding 100%. These...

OCC Rent A Bank Rule Proposal Comment Letter 2020

The Center for Responsible Lending and the National Consumer Law Center (on behalf of its low income clients), as part of a coalition of consumer and civil rights groups wrote the comment letter included on this page, which details the groups' strong opposition to a proposed rule from the Office of the Comptroller of the Currency (OCC)’. The proposed rule...

Comment: Faith Leaders on HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard

"As pastors and faith leaders, our sacred text teaches us to care for our neighbors and see the dignity of all of God’s people. Of all the issues confronting Americans, none is more basic than that of housing. Whether renting or owning a home, every family needs a place to come home to at the end of the day. It...