Policy & Legislation

A legacy of racial discrimination in housing, lending, banking, policing, employment, and otherwise, has produced dramatically inequitable outcomes that persist today. Communities of color, often largely segregated due to the history of redlining and other racially exclusionary housing policy, experience higher rates of poverty, lower wages, and higher cost burdens to pay for basic living expenses. Payday loans cause particular...

Ten years after the Great Recession, the current economic contraction is again hitting Black and Brown communities and lower-wage workers the hardest – many of whom have never recovered. This crisis is worsening long-standing and growing racial and economic inequities at the very moment of national reckoning with the historic need for their redress. Too often, predatory financial services and...

Opportunity in America has never been evenly distributed, but the gains made over the last 100 years are at risk if a conservative Justice is added to the Supreme Court. Just like the many social issues already being covered in the wake of President Trump’s Supreme Court nomination, the nine justices who fill the seats of America’s highest court will...

Prior to the COVID-19 crisis, court fines and fees, and other monetary sanctions overly burdened young people and adults involved in the criminal legal system with debt from pre-trial through post-release and beyond. A few months into the crisis, we are seeing that Black and Brown communities are disproportionately facing economic challenges. This is reflected in national unemployment data, where...

The Consumer Financial Protection Bureau (CFPB), under Director Kathy Kraninger, gutted a 2017 CFPB rule aimed at stopping the debt trap caused by payday and car title loans. This action will have a harmful impact on American consumers and their families, including a disproportionate number of people of color. Download the one-pager to learn more.

For years, predatory lenders have sought ways to avoid state interest rate limits. One scheme has been the “rent-a-bank” scheme. Under this scheme, a non-bank lender finds a bank willing to be the nominal originator of the non-bank lender’s high-cost loan, because banks are generally exempted from complying with state interest rate laws. State regulators, state attorneys general, and consumers...

Industrial loan companies (ILCs) or industrial banks (IBs) (together, “ ILCs”) typically enjoy the privileges of traditional banks but pose two significant risk factors unique to ILCs: They are not subject to the Federal Reserve’s supervision, which occurs at the consolidated level (i.e., the ILC’s parent company, the ILC, and their affiliates); and They permit the intermingling of commercial and...

The Problem High-cost lenders are ignoring state law and continuing to lend high above the state's legal interest rates, using a practice called Rent-A-Bank. In some cases, these rates are under 36% on very large loans. In others, rates are in the triple-digits, charging consumers up to 200% to finance car repairs, furniture, and even puppies. How Rent-A-Bank Works In...

On May 20, 2020, the Office of the Comptroller of the Currency (OCC) acted alone in issuing a structurally flawed final rule on the Community Reinvestment Act (CRA) that weakens the CRA and will harm low- and moderate-income (LMI) communities and communities of color. Rather than postpone rulemaking to focus on the devastating economic crisis caused by the COVID-19 health...

The Paycheck Protection Program (PPP) is a revenue replacement program designed to sustain small business jobs during the ongoing public health and economic crisis. The effect of the crisis on small businesses has been profound—over half of small businesses said the crisis has had a large negative effect on their businesses and 74% of small businesses said they have had...