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.
- 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).
- 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 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.
- Comments to CFPB on Overdraft Practices
July 6, 2012
CRL joined with CFA and NCLC to provide the CFPB (Consumer Financial Protection Bureau) with documentation of bank overdraft practices and their impact on consumers. The CFPB should stop banks from reordering transactions and should prohibit overdraft fees on debit card transactions, which can easily be declined at no cost.
- Comments to the Consumer Financial Protection Bureau on Payday Lending Abuses
April 23, 2012
Comments to the Consumer Financial Protection Bureau on payday lending abuses on behalf of several organizations concerned about the documented abuses of payday lenders.
- Comments to CFPB re Larger Participant Rulemaking
August 15, 2011