Comment Letter

The proposed rule will have a toxic effect on the mortgage lending industry. The Fair Housing Act’s disparate impact doctrine has played a critical role in making fair housing available to all, while at the same time making the lending industry better at evaluating creditworthiness. A ban on unjustified disparate impact has encouraged the lending industry to systematically scrutinize its...

The Center for Responsible Lending (CRL), The Leadership Conference on Civil and Human Rights, NAACP, National Urban League, and UnidosUS appreciate the opportunity to respond to the Consumer Financial Protection Bureau’s (CFPB or Bureau) Advance Notice of Proposed Rulemaking (ANPR) on the Qualified Mortgage (QM) definition under the Truth in Lending Act (TILA) and Ability to Repay / Qualified Mortgage...

The 232 undersigned consumer, civil and human rights, labor, community and legal services organizations from all 50 states and the District of Columbia submit the following comments on the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed debt collection rules. The rule as proposed does far more to protect abusive debt collectors than consumers. The proposal opens consumers up to...

The undersigned consumer and civil rights organizations appreciate the opportunity to submit comments on the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed rule on debt collection. As organizations dedicated to eliminating abusive financial practices – particularly focused on communities of color and low- to moderate-income consumers – we are deeply concerned about the proposed rule’s content and impact. Without...

The Center for Responsible Lending (CRL) files this comment in response to the U.S. Department of Education’s proposed rule that would amend the Borrower Defense to Repayment provision of the Higher Education Act (HEA) and rescind and rewrite previously promulgated regulations from 2016. CRL is extremely concerned about the Department’s decision to rewrite rules meant to protect students and taxpayers...

The Center for Responsible Lending (CRL) files this comment in response to the above referenced U.S. Department of Education’s Notice of Proposed Rulemaking (NPRM) which rescinds the 2014 gainful employment (GE) regulations. CRL is deeply troubled by the Department’s decision to do away with these important accountability requirements that protect both the welfare of career training students and the taxpayer...

The considerations prescribed by the RFA strongly support strengthening protections against overdraft fees on debit card and ATM transactions. More broadly, comprehensive reform of unfair and abusive overdraft practices is badly needed. The RFA sets forth five factors to consider in an RFA review. Consideration of these factors in the opt-in rule context shows clearly that any effort to weaken...

The 24 undersigned community, consumer, civil rights, and faith groups write regarding the Consumer Financial Protection Bureau (CFPB or the Bureau)’s review of the 2009 Regulation E overdraft opt-in rule under the Regulatory Flexibility Act (RFA). Weakening the opt-in rule in any way is clearly unsupportable; rather, protections against unfair and abusive overdraft fees should be substantially strengthened. Today’s overdraft...

"Regarding State Authorization of Distance Education providers enrolling students across multiple states, we voice here our support for those provisions of the NPRM that preserve the State Authorization rules finalized in 2016 and currently in effect. The 2016 rules provide core protections to consumers and protect states’ rights to enforce their own laws in two key areas. First, the rules...

A coalition of national consumer and civil rights groups wrote letters to three top banking regulators – the FDIC, OCC and Federal Reserve – on the importance of preventing the reemergence of debt-trap bank payday loans. View the letter to the FDIC, letter to the OCC, and letter to the Fed. These letters were signed by Americans for Financial Reform...