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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- Small Loan CRA Comment
February 2, 2007CRL Comment to the Federal Deposit Insurance Corporation on its proposed guidelines for affordable small-dollar loans.
- Debit Card Danger
January 25, 2007CRL report includes an analysis of bank account information and a survey of account holders, finds that bank customers have more overdrafts caused by a debit card purchase than by a written check, debit card overdrafts are more costly, and survey respondents would avoid the fees if given the choice.
- CRL Review of "Defining and Detecting Predatory Lending" by Donald P. Morgan, Federal Reserve Bank of NY, January 2007
January 23, 2007CRL critiques faulty research report by Don Morgan, which attempts to compare states with and without payday lending but misidentifies many of those states.
- Losing Ground: Foreclosures in the Subprime Market and Their Cost to Homeowners
December 19, 2006Comprehensive, nationwide review of millions of subprime mortgages originated from 1998 through 3Q06. Report projected lifetime foreclosure rates for 2006-originated subprime loans in each MSA in the United States.
- Financial Quicksand: Payday lending sinks borrowers in debt with $4.2 billion in predatory fees every year
November 30, 2006CRL research report finds that payday lending costs Americans $4.2 billion per year in fees.
- Comment: Proposed FDIC Survey of Overdraft Loan Programs
October 16, 2006Proposed FDIC Survey of Overdraft Loan Programs
- CRL Comment on Federal Reserve Analysis of Home Mortgage Disclosure Act Data
October 9, 2006Debbie Bocian's comment on the Fed's analysis of 2005 HMDA data.
- Calculated Risk: Assessing Non-Traditional Mortgage Products
September 20, 2006Calhoun urges federal regulators to require subprime lenders to evaluate borrower’s ability to repay before making a mortgage loan, and also by strengthening enforcement against unscrupulous lenders
- CRL Comment on OCC Working Paper #2006-1, "Foreclosures of Subprime Mortgages in Chicago"
September 15, 2006CRL disputes the findings of an OCC study of subprime mortgage foreclosures in Chicago
- Comment: Home Ownership and Equity Protection Act Hearings
August 15, 2006Public hearings on the home equity lending market and the adequacy of existing regulatory and legislative provisions in protecting the interests of consumers.
- Georgia's Payday Loan Law: A Model for Preventing Predatory Payday Lending
June 29, 2006Brief analysis of Georgia's law preventing payday lenders from circumventing their consumer credit interest rate cap and other protections.
- Home Mortgage Disclosure Act: Newly Collected Data and What It Means
June 13, 2006Ernst proposes ways to strengthen the Home Mortgage Disclosure Act (HMDA)
- Unfair Lending: The Effect of Race and Ethnicity on the Price of Subprime Mortgages
May 31, 2006Reports that African American and Latino buyers more likely then Whites to get subprime loans with same credit scores
- Overdraft Loans: Survey Finds Growing Problem for Consumers
April 24, 2006CRL survey finding sixteen percent of overdraft loan users account for 71 percent of fee-based overdraft loan fees. Repeat users are more often low-income, single, non-white renters.
- Comment: Proposed Interagency Guidance on Nontraditional Mortgages
March 29, 2006This letter highlights concerns with nontraditional mortgages in the subprime market.
- The Costs of Subprime Prepayment Penalties: A Response to "Call Protection in Mortgage Contracts"
March 1, 2006CRL disputes the findings of Michael LaCour-Little's paper and points out 3 significant shortcomings
- Brief: Owners, Lenders Flourish Under State Anti-Predatory Lending Laws
March 1, 2006“The Best Value in the Subprime Market: State Predatory Lending Reforms” shows that state laws are working well for credit-strapped families in the subprime market and for responsible lenders.
- The Best Value in the Subprime Market: State Predatory Lending Reforms
February 23, 2006 - Highlights from Report on Tennessee's Title Lending Industry
February 15, 2006Highlights from title lending report from Tennessee.
- An Attack without Merit
February 14, 2006Payday loan industry pays Prof. Thomas Lehman to challenge CRL’s research, but none of his criticisms are accurate.

























