CRL rebuts working paper on minority homeownership, citing fundamental flaws and conclusions.

CRL compares the dual track foreclosure restrictions and requirements in the National Mortgage Settlement, the California Homeowner Bill of Rights and related rules from the Consumer Financial Protection Bureau.

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.

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.

Congress should not allow high fees and loopholes to return to mortgage lending. HR.1077 will lead to more expensive and dangerous loans for borrowers.

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.

Asregulators move to define Qualified Residential Mortgages (QRMs), CRL urges the same standard that CFPB defined for Qualified Mortgages (QM).

This brief urges state actions to prevent avoidable foreclosures with a Homeowner Bill of Rights

National and statewide consumer groups are urging that the Home Affordable Modification Program (HAMP) be extended, citing success in foreclosure prevention and modification.

Banks making payday loans continue to trap customers in a cycle of debt, according to a CRL study, "Triple-Digit Danger: Bank Payday Lending Persists." Banks pitch payday loans as short-term borrowing that allows customers to deal with a financial emergency, repay the loan, and move on. In fact, this new study provides further evidence that these triple-digit interest rate loans, averaging from 225% to 300% APR, trap borrowers in a long-term cycle of repeat loans.

CRL's analysis of "Ongoing Implementation",a report on 2012 efforts under the National Mortgage Settlement to halt foreclosures through loan modifications, and other assistance.

States are in a strong position to prevent unnecessary foreclosures, stabilize local housing markets and protect homeowners from mortgage servicing abuses. Through practical enhancements to the standards set by the Consumer Financial Protection Bureau (CFPB) and California’s Homeowner Bill of Rights, states can help borrowers get full and fair consideration for loan modifications before losing their homes to foreclosure.

Research from CRL and Consumer Federation of America finds that car-title loans cost U.S. consumers $3.6 billion in interest on $1.6 billion in loans. According to the research, car-title lenders operate 7,730 stores in at least 21 states and make 1.7 million loans annually.

On February 23, the New York Times published an article describing how some banks enable Internet payday lending. In this brief, CRL provides additional legal context to supplement that article. Bottom line: We need to continue passing state laws that provide strong enforcement tools, and federal regulators need to use their full authority to stop predatory payday loans.

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 identifies some problems with CoreLogic's QM analysis of the percent of mortgage loans that would not meet QM standards

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.