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 on Proposed Reg Z Rules Re Implementation of Credit Card Act Provisions
April 14, 2010
CRL and other consumer groups comments to the Federal Reserve on proposed credit card rules related to the implementation of the Credit CARD Act and penalty rates and fee increases.
- Comments to the Federal Trade Commission on Mortgage Assistance Relief
March 30, 2010
The need for mortgage relief continues to grow, but too often companies that promise mortgage assistance relief services (MARS) turn out to be scammers. CRL and its allies recently submitted comments to the Federal Trade Commission, which is considering tighter rules to ensure that people who pay for mortgage assistance actually have a fair chance of receiving help.
- 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.
- Federal Reserve Should Ban Mortgage Kickbacks
December 24, 2009
In a comment letter to the Federal Reserve Board, CRL recommends strengthening proposed rules to ban routine kickbacks on home loans that already have cost Americans billions of dollars.
- Comment: Proposed 2009 GSE Housing Goals
May 22, 2009
CRL's comments on proposed housing goals for Fannie Mae and Freddie Mac support incentives to modify distressed mortgages.
- 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.
- Comments: Proposed changes to HMDA reporting requirements
August 28, 2008
CRL's comment on Fed's proposed changes to HMDA reporting requirements.
- Comment: Proposed Rule Regarding Unfair or Deceptive Acts or Practices – Overdraft Practices
August 4, 2008
Overdraft comment letter
- Comment: Unfair or Deceptive Practices with Respect to Credit Cards
August 4, 2008
Comments on Federal Reserve Board proposals regarding unfair and deceptive credit card practices, August 4, 2008.
- 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: RESPA Proposed Rule to Simplify and Improve the Process of Obtaining Mortgages to Reduce Consumer Settlement Costs
June 12, 2008
Comments of the Center for Responsible Lending on RESPA Proposed Rule to Simplify and Improve the Process of Obtaining Mortgages to Reduce Consumer Settlement Costs
- Comment: Proposed Rules Regarding Unfair, Deceptive, Abusiveprotect consumers from unfair or deceptive home mortgage lending and advertising practices
April 8, 2008
Request for comment on proposed changes to Regulation Z (Truth in Lending) to protect consumers from unfair or deceptive home mortgage lending and advertising practices. The rule, which would be adopted under the Home Ownership and Equity Protection Act (HOEPA), would restrict certain practices and would also require certain mortgage disclosures to be provided earlier in the transaction.
- Comment: Guidance Regarding Marketing of Refund Anticipation Loans (RALs) and Certain Other Products in Connection With the Preparation of a Tax Return
April 7, 2008
While we believe that many commercial RALs are abusive financial products that should not be available to consumers without significant protections beyond those currently available, we understand that the IRS does not have jurisdiction over the banks that make these loans.
- 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: Proposed Interagency Statement on Subprime Mortgage Lending
May 7, 2007
The Center for Responsible Lending submits the following comments on the proposed Interagency Statement on Subprime Mortgage Lending.
- 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.
- Comments on the North Carolina Commissioner of Banks' Proposed Guidance on Non-Traditional Mortgage Risks
February 7, 2007
Comments on the North Carolina Commissioner of Banks' Proposed Guidance on Non-Traditional Mortgage Risks
- 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
- CRL Comment on Federal Reserve Analysis of Home Mortgage Disclosure Act Data
October 9, 2006
Debbie Bocian's comment on the Fed's analysis of 2005 HMDA data.