Research & Analysis
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CRL conducts in-depth research on the extent and impact of predatory lending, to provide useful information to consumers, community advocates, and policymakers alike. We also share our market and legal knowledge with advocates and policymakers across the nation interested in reforming lending practices. Below you will find CRL research and analyses on a range of topics.
Want more information? Go to the Tools & Resources page, or check out our Resources for Consumers, Policymakers, Allies, and Litigators pages. A good external source for research on predatory lending and related issues is www.knowledgeplex.org
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- Minority Homeownership Study Has Flawed Methodology and Conclusions
June 13, 2013
CRL rebuts working paper on minority homeownership, citing fundamental flaws and conclusions.
- Comparing Dual Track Foreclosure Restrictions
June 13, 2013
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 Comment to CFPB on Amendments to 2013 Mortgage Rule
June 3, 2013
- 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.
- Consumer Advocates Urge FHFA to Curb Lender-Placed Insurance Problems
May 28, 2013
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.
- HR 1077 Would Weaken Mortgage Reforms in Dodd-Frank
May 20, 2013
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.
- All Federal Credit Unions Should Shun Payday Lending
May 16, 2013
- 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.
- CRL to Regulators: Align Qualified Mortgage (QM) and Qualified Residential Mortgage (QRM) mortgage rules
April 22, 2013
Asregulators move to define Qualified Residential Mortgages (QRMs), CRL urges the same standard that CFPB defined for Qualified Mortgages (QM).
- Closing the Gaps: What States Should Do to Protect Homeowners From Foreclosure
April 8, 2013
This brief urges state actions to prevent avoidable foreclosures with a Homeowner Bill of Rights
- Consumer Advocates Urge HAMP Extension
March 26, 2013
National and statewide consumer groups are urging that the Home Affordable Modification Program (HAMP) be extended, citing success in foreclosure prevention and modification.
- Triple-Digit Danger: Bank Payday Lending Persists
March 21, 2013
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.
- Analysis of the Report of the Monitor of the National Mortgage Settlement
March 20, 2013
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.
- CRL to Senate Banking Committee: Confirm CFPB's Cordray
March 19, 2013
- State Actions Still Needed to Prevent Unnecessary Foreclosures
March 4, 2013
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.
- Driven to Disaster: Car-Title Lending and Its Impact on Consumers
February 28, 2013
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.
- New York Times Article on Banks Aiding Payday Loans: There's Even More to the Story
February 26, 2013
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 Comment to CFPB on Ability to Repay Standards under the Truth in Lending Act (Regulation Z)
February 25, 2013
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 Response to CoreLogic Analysis of Qualified Mortgage (QM) Standards
February 20, 2013
CRL identifies some problems with CoreLogic's QM analysis of the percent of mortgage loans that would not meet QM standards
- CRL tells CFPB the CARD Act Works, Encourages Risk-based Pricing
February 19, 2013
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.