Comments to Regulators
CRL's staff includes attorneys, researchers, and policy analysts in North Carolina, Washington DC, and California who study and report on predatory lending matters, and monitor legislative and regulatory activity in state capitols and in the nation's capitol. CRL frequently responds to regulators' requests for comments on lending issues. Read our written comments to regulators.
- Comments by CRL and other Consumer Advocates to Department of Defense: Limitations on Terms of Consumer Credit
August 1, 2013
The Department of Defense is currently considering public comments and recommendations from other regulators on strengthening protections under the Military Lending Act. CRL and other groups have urged the DoD to significantly broaden the definition of credit covered under the law's 36% APR limit to include, among other products, all payday loans regardless of how they are structured or how long their term is.
- CRL Comment to CFPB on Amendments to 2013 Mortgage Rule
June 3, 2013
- Advocates Support Proposed Restrictions on Bank Payday Lending
May 30, 2013
CRL and allies urge the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) to implement and strengthen their proposed guidance to restrict "deposit advance" (i.e., payday loans) by the banks they supervise. AARP, Consumer Federation of America, the Leadership Conference on Civil and Human Rights, the NAACP, the National Consumer Law Center and the National Council of La Raza joined CRL in submitting these comments.
- Consumer Advocates Urge FHFA to Curb Lender-Placed Insurance Problems
May 28, 2013
In this comment to the Federal Housing Finance Agency (FHFA), CRL and seven allies comment on proposed practice limitations and broader recommendations regarding lender-placed insurance (LPI). LPI markets are characterized by reverse competition in which LPI premiums paid by mortgage servicers and LPI amounts subsequently charged to borrowers and investors areinflated because LPI insurers/vendors compete for the servicers’ business by providing considerations – kickbacks – to the servicers and including the cost of these considerations in the LPI premiums and LPI amounts charged to borrowers and investors. The extent of the overcharges is demonstrated by the very low loss ratios (claims incurred divided by premiums earned) of LPI compared to loss ratios for homeowners insurance. LPI charges to borrowers and investors are at least twice the reasonable cost of providing LPI. In addition, excessive LPI charges to borrowers and the government-sponsored enterprises (GSEs) are a source of servicer-induced foreclosures, and such excessive charges are also inconsistent with the mission and affordable housing goals of the GSEs. For these reasons, CRL and its allies support the direct purchase by GSEs of LPI and insurance tracking services and support prohibitions against kickbacks from LPI insurers/vendors to mortgage servicers.
- All Federal Credit Unions Should Shun Payday Lending
May 16, 2013
- Banks Should Disclose Overdraft Fees
May 9, 2013
Today banks are allowed to report overdraft fees as part of general service charge income, but CRL supports greater transparency. In this comment letter to the Federal Financial Institutions Examination Council (FFIEC), CRL supports a current proposal requiring separate accounting for overdraft-related fees. CRL also urges separate reporting for overdraft fees triggered by debit card purchases and ATMs versus overdraft fees triggered by checks and automated clearinghouse transactions.
- CRL Comment to CFPB on Ability to Repay Standards under the Truth in Lending Act (Regulation Z)
February 25, 2013
CRL and allies comment on CFPB proposal that addresses two issues critical to the future of safe, sustainable, and affordable access to mortgage credit. First, it considers how to define compensation for the purpose of calculating the points and fees cap contained in the qualified mortgage definition. Second, it proposes a series of exemptions for specialized lending programs and financial institutions.
- CRL tells CFPB the CARD Act Works, Encourages Risk-based Pricing
February 19, 2013
Comments submitted by the Center for Responsible Lending to the Consumer Financial Protection Bureau in response to the Request for Information Regarding Credit Card Market. The CARD Act has made pricing clearer without restricting credit, raising its cost or curbing the ability of card issuers to price for risk. Contrary to curbing risk-based pricing, the CARD Act encourages risk-based pricing.
- CRL Comments to CFPB 0n Proposed Remittance Transfer Rule
January 29, 2013
Comments submitted by CRL and National Council of La Raza concerning the proposed revision of theConsumer Financial Protection Bureau to its final rulemaking onremittance transfers under the Electronic Fund Transfers Act (EFTA).
- U.S. Senators ask Regulators to Stop Bank Payday Lending
January 7, 2013
Five U.S. Senators have asked the OCC, the FDIC and the Federal Reserve to stop the banks under their respective jurisdictions from making predatory payday loans. At least four big banks have started making the triple-digit interest loans, which are virtually identical to the predatory payday loans that trap borrowers in long-term, high-cost harmful debt.
- CRL Comments on Proposed Rules for NCUA Payday Alternatives Loan Program
November 30, 2012
CRL urges the NCUA to structure their Payday Alternatives Loan (PAL) program to reflect the broad range of alternatives, to prevent the program from operating like a series of high-cost payday loans and to prevent credit unions from engaging in payday lending outside of the PAL program.
- CRL and NCLC Comments on Wells Fargo Payday Lending and CRA Examination
November 29, 2012
Wells Fargo's direct engagement in payday lending should have a significant negative impact on their upcoming Community Reinvestment Act evaluation.
- CRL Comments To the Consumer Financial Protection Bureau RE: Truth in Lending Act (Regulation Z) and Loan Originator Compensation
October 16, 2012
CRL affirms that limits on loan originator compensation contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act and in Regulation Z are important consumer protections that fundamentally improve the mortgage market, and offers some suggestions for improving standards proposed by CFPB.
- Making Mortgage Servicing More Effective: Comments to the CFPB
October 9, 2012
In comments submitted to the Consumer Financial Protection Bureau, CRL makes a number of recommendations to help ensure loan servicers give distressed mortgages a timely, efficient and comprehensive review to mitigate losses. The CFPB's proposed rulemaking is under the Real Estate Settlement Procedures Act (RESPA).
- CRL Comments to the Consumer Financial Protection Bureau on RESPA and TILA (Regulations X and Z)
September 7, 2012
CRL offers supports the Bureau's consumer protection proposal for mortgage rules and disclosures for high-cost (HOEPA) loans. But it urges CFPB to be vigilant about evasions of HOEPA and to adopt a regulation that is expansive enough to capture all loans structured to evade HOEPA.
- Letter to Regulators on Down Payments (QRM Requirements)
August 30, 2012
CRL and six other organizations submit comments to regulators explaining why government-mandated down payments would be damaging to lower- and middle-income families and the housing market as a whole.
- Comment to CFPB: The financial exploitation of older Americans
August 20, 2012
CRL told the CFPB of abusive financial practices against older Americans. More than 13 million older adults live on $21,800 a year or less. Further, the average credit card debt for these consumers is now more than $9,000 – the highest average balance of any group.
- Comments on Enterprise Housing Goals
July 31, 2012
The Center for Responsible Lending, Consumer Federation of America, and Empire Justice Center submitted comments to the Federal Housing Finance Agency on a proposed rule for the 2012-2014 Enterprise Housing Goals. "It is critical that FHFA continue to focus on its responsibility of ensuring that the Enterprises serve the entire housing market." The Enterprises can do this while fostering a liquid, competitive and strong housing market.
- CRL Tells CFPB: Prepaid Cards Lack Consumer Protections
July 24, 2012
The CFPB should prohibit overdraft and credit features on prepaid cards.
- Comments on Qualified Mortgages to the Consumer Financial Protection Bureau
July 9, 2012
The Center for Responsible Lending, Consumer Federation of America and The Leadership Conference on Civil and Human Rights responded to the CFPB's request for comments on qualified mortgages. Much of the comment letter focuses on an appropriate "bright line" debt-to-income ratio standard for QMs. Setting a narrow debt-to-income ratio for QMs would unnecessarily exclude a large share of borrowers from QM protections. This letter supports setting a baseline debt-to-income ratio on QMs while also giving lenders flexibility to go above it by considering other "compensating factors" that affect a borrower's ability to handle a loan successfully.