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.
- 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.
- 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.
- AFR Sign-on to OCC on Overdraft and Bank Payday
August 9, 2011
Consumer groups fear OCC proposed guidance may legitimize and facilitate the spread of payday lending by national banks, and banks would continue abusive overdraft practices—harming bank customers, undermining state payday loan laws, and weakening the long-term safety and soundness of financial institutions.
- Comments to OCC on Overdraft and Bank Payday Loans
August 9, 2011
CRL filed comments to the OCC on August 8, 2011 urging them to strengthen rules on overdraft and bank payday lending. Automatic debit overdrafts, re-ordering of account transactions and direct deposit personal loans or bank payday loans unfairly strip fees from consumers.
- Joint Letter in Support of FDIC Overdraft Proposals September 2010
September 27, 2010
CRL and a cross-section of civil rights, labor, consumer, housing, community, business, and sustainable and responsible investor groups sent a joint letter to the FDIC expressing support for bringing attention to abusive overdraft practices. The groups support the agency’s common-sense recommendations for actions banks should take to treat their customers more fairly while offering recommendations for how the FDIC could further address its banks deceptive practices.
- Comment Letter on FDIC's Proposed Overdraft Guidance
September 27, 2010
CRL and other consumer advocates filed a comment letter with the FDIC supporting most aspects of the agency's proposed guidance on overdraft. The groups also made recommendations on how the agency could go even further in protecting consumers from excessive overdraft fees.
- Guidance to OTS on Overdraft Protection Programs
June 28, 2010
CRL’s, Consumer Federation of America and the National Consumer Law Center’s comment letter to the OTS regarding the agency’s Supplemental Guidance on Overdraft Protection Programs.
- CRL Comment Letter on Garnishment of Federal Benefits
June 18, 2010
CRL and other consumer groups provide comment on the Office of Personnel Management's proposed rule regarding garnishment of federal benefits.
- CRL and Other Groups Comment on Clarifications to Fed's Opt-In Rule
March 30, 2010
CRL and other consumer groups provide comment on the Federal Reserve’s opt-in rule and the proposed changes to Regulation DD.
- Comments on Regulation E—Overdraft Practices
March 30, 2009
The Center for Responsible Lending, along with Consumer Action, Consumer Federation of America, Consumers Union, National Association of Consumer Advocates, National Consumer Law Center (on behalf of its low-income clients), and U.S. PIRG provide the following comments regarding the Federal Reserve Board’s proposed rule to amend Regulation E pursuant to the Electronic Funds Transfer Act.
- Comment: Proposed Rule Regarding Unfair or Deceptive Acts or Practices – Overdraft Practices
August 4, 2008
Overdraft comment letter
- Comments on proposed Regulation DD amendments re Overdraft Lending
July 18, 2008
America, Consumers Union, and the National Consumer Law Center, provide the following comments regarding the Federal Reserve Board’s proposed rule to amend Regulation DD pursuant to the Truth in Savings Act (TISA).
- Comment: Implementation of Military Lending Amendment
February 26, 2008
Comments on Implementation of Limitations on Terms of Consumer Credit Extended to Service Members and Dependents
- Small Loan CRA Comment
February 2, 2007
CRL Comment to the Federal Deposit Insurance Corporation on its proposed guidelines for affordable small-dollar loans.
- Comment: Proposed FDIC Survey of Overdraft Loan Programs
October 16, 2006
Proposed FDIC Survey of Overdraft Loan Programs