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.
- 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.
- All Federal Credit Unions Should Shun Payday Lending
May 16, 2013
- 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.
- 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.
- 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 on NCUA's Notice of Proposed Rulemaking on Short-term, Small Amount Loans
July 6, 2010
Comments of the Center for Responsible Lending on the Notice of Proposed Rulemaking on Short-term, Small Amount Loans from National Credit Union Administration--12 CFR Part 701--RIN 3133-AD71. Submitted July 6, 2010.
- 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
- Comment: To Department of Defense on Military Lending Act
February 8, 2007
Comments on Military Lending Act submitted to Department of Defense by Consumer Coalition on Feb. 5, 2007.
- Small Loan CRA Comment
February 2, 2007
CRL Comment to the Federal Deposit Insurance Corporation on its proposed guidelines for affordable small-dollar loans.
- Comments: RIN 3064-AC95, Proposed Rulemaking on Federal Preemption
December 13, 2005
The Center for Responsible Lending submits these comments on the proposed rules, ere part of a larger package of preemption rules urged upon the FDIC by the Financial Services Roundtable.