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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- The State of Lending: America's Household Balance Sheet
December 12, 2012
This chapter in the State of Lending report series describes the overall financial status of U.S. households today--their income, spending, debts, and wealth. It tells the story of financial challenges that consumers have faced in the past decade, and how these have made Americans more vulnerable to predatory lending. It also describes how household financial health is central to our nation's economic well-being.
- The State of Lending: Student Loans
December 12, 2012
A college education is critical in today's competitive job market. but post-secondary education has never been more expensive. Most U.S. families rely on student loans to help finance a college educationand total U.S. student loan debt now exceeds $1 trillion. This chapter discusses key differences between federal and higher-cost private student loans, increases in student defaults on loans to students at for-profit colleges, and ways to make financing options clearer to students and parents.
- 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.
- Congress: Extend Mortgage Forgiveness Debt Relief Act
November 29, 2012
Center for Responsible lending joined with Financial Services Roundtable and Housing Policy Council to ask Congress to extend the Mortgage Forgiveness Debt Relief Act.
- Collateral Damage: The Spillover Cost of Foreclosures
October 24, 2012
When families lose their homes to foreclosure, their nearby neighbors lose value on their properties. This report estimates this "spillover" cost nationwide will be nearly $2 trillion. Over half of that spillover cost is being borne by neighborhoods of color.
- CRL Comments To the Consumer Financial Protection Bureau RE: Truth in Lending Act (Regulation Z) and Loan Originator Compensation
October 16, 2012
CRL affirms that limits on loan originator compensation contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act and in Regulation Z are important consumer protections that fundamentally improve the mortgage market, and offers some suggestions for improving standards proposed by CFPB.
- Making Mortgage Servicing More Effective: Comments to the CFPB
October 9, 2012
In comments submitted to the Consumer Financial Protection Bureau, CRL makes a number of recommendations to help ensure loan servicers give distressed mortgages a timely, efficient and comprehensive review to mitigate losses. The CFPB's proposed rulemaking is under the Real Estate Settlement Procedures Act (RESPA).
- Foreclosure Counseling: Areas of Greatest Need
October 3, 2012
This research brief identifies which metro and rural areas are hardest hit by foreclosures and remain areas of greatest need for additional foreclosure counseling resources.
- The Future of Homeownership
September 21, 2012
After years of steady progress, the homeownership rate in America has seen its biggest drop since the Great Depression. Today we have an opportunity to return to a stable lending environment with rising homeownership.
- CRL Comments to the Consumer Financial Protection Bureau on RESPA and TILA (Regulations X and Z)
September 7, 2012
CRL offers supports the Bureau's consumer protection proposal for mortgage rules and disclosures for high-cost (HOEPA) loans. But it urges CFPB to be vigilant about evasions of HOEPA and to adopt a regulation that is expansive enough to capture all loans structured to evade HOEPA.
- Qualified Residential Mortgages: Down Payment Rules Threaten Home Buyers—and the Economy
August 31, 2012
The housing market of the future can drive economic growth without shutting out responsible home buyers. Find reports, data and other resources on Qualified Residential Mortgages.
- A Government-Mandated 10% Down Payment: Bad for Families, the Housing Market and the Economy
August 31, 2012
Decades of lending have shown that low down payment lending can be successful. Excluding millions of good borrowers from the mainstream mortgage market would be a serious mistake.
- Letter to Regulators on Down Payments (QRM Requirements)
August 30, 2012
CRL and six other organizations submit comments to regulators explaining why government-mandated down payments would be damaging to lower- and middle-income families and the housing market as a whole.
- "Qualified Residential Mortgages" -- the Negative Impact of a Government-Mandated 10 Percent Down Payment
August 29, 2012
On August 29, 2012, CRL and several other organizations submitted a letter to federal and financial regulators opposing a government-mandated down payment requirement as part of the pending definition of “Qualified Residential Mortgages (QRMs).” Regulators are considering imposing minimum down payment requirements as part of QRM standards. While much has been written on the barriers to homeownership that would result from the 20 percent down payment requirement included in regulators’ April 2100 proposed rule, there has been less commentary on a possible 10 percent down payment.
- H.R. 6139: Payday Lender Carve-out Will Undermine Consumer Financial Protection Bureau and States
August 27, 2012
Carve-outs for payday lenders will undermine state protections and CFPB.
- Comment to CFPB: The financial exploitation of older Americans
August 20, 2012
CRL told the CFPB of abusive financial practices against older Americans. More than 13 million older adults live on $21,800 a year or less. Further, the average credit card debt for these consumers is now more than $9,000 – the highest average balance of any group.
- Comments on Enterprise Housing Goals
July 31, 2012
The Center for Responsible Lending, Consumer Federation of America, and Empire Justice Center submitted comments to the Federal Housing Finance Agency on a proposed rule for the 2012-2014 Enterprise Housing Goals. "It is critical that FHFA continue to focus on its responsibility of ensuring that the Enterprises serve the entire housing market." The Enterprises can do this while fostering a liquid, competitive and strong housing market.
- No Credit Crunch: The CFPB and Consumer Access to Credit
July 24, 2012
Mike Calhoun, CRL President, testified that lack of regulation led to the foreclosure crisis. The Dodd-Frank reforms and CFPB are important reforms to prevent a future housing crisis, and will be good for consumers and the safety and soundness of our consumer finance system. Testimony was before a subcommittee of the House Committee on Oversight and Government Reform.
- The Impact of Dodd-Frank's Home Mortgage Reforms
July 11, 2012
CRL Senior Vice President Eric Stein emphasized the importance of defining "Qualified Mortgage" broadly to avoid shutting out creditworthy borrowers from the mortgage market. He recommended that QM include the use of specific "bright-line" standards so that lenders and borrowers are clear on which loans qualify as QMs. He also made the case for allowing borrowers to pursue legal action if an alleged QM loan failed to meet the appropriate standards from the outset. This testimony was presented before the House of Representatives Committee on Financial Services - Subcommittee on Financial Institutions and Consumer Credit.