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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- 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.
- Expanding, Streamlining Mortgage Refinances
June 27, 2012
The Boxer-Menendez bill to expand refinances offers a bipartisan opportunity to help homeowners and boost the economy. The bill would more than double the number of homeowners who could refinance under the Home Affordable Refinance Program (HARP) and also more than double their savings, according to research by the Columbia University Business School.
- FDIC Promises Investigation of Bank Payday Lending
May 31, 2012
The FDIC has promised that to make investigation of bank payday lending a priority investigation. In response to a letter submitted by 250 advocates, Acting Chairman Martin Gruenberg said the banking regulator is concerned that banks are violating guidelines for fair and affordable products.
- Are prepaid credit cards helping or hurting consumers?
May 25, 2012
Martin Eakes remarks on prepaid cards before a CFPB field hearing.
- Predatory Credit Card Lending: Unsafe, Unsound for Consumers and Lenders
May 8, 2012
What hurts consumers financially hurts business. Losses in downturns mount faster at banks enagaging in unfair, deceptive practices. High-cost penalty fees, interest rates don’t mitigate risk—as credit card issuers have said—but instead are the risk that causes consumers to default.
- California Foreclosure Statistics: The Crisis is Not Over
April 26, 2012
Compilation of California foreclosure statistics through 2011 from a variety of sources, including Center for Responsible Lending, DataQuick and the Mortgage Bankers Association.
- Comments to the Consumer Financial Protection Bureau on Payday Lending Abuses
April 23, 2012
Comments to the Consumer Financial Protection Bureau on payday lending abuses on behalf of several organizations concerned about the documented abuses of payday lenders.
- Deal or No Deal: How Yo-Yo Scams Rig the Game against Car Buyers
April 4, 2012
This latest paper by CRL provides a clear picture of the prevalence of yo-yo scams, insight into how yo-yo scams are perpetrated, and identifies which consumers are most likely to be targeted by dealers for this scam.
- Summary of National Mortgage Settlement
March 14, 2012
Forty-nine state attorneys generals and two government agencies have reached a $25 billion agreement with the nation's five largest mortgage servicers to address mortgage loan servicing and foreclosure abuses. Here we provide a quick-reference summary of the terms of this agreement.
- The Party’s Over for Quickie Tax Loans: But Traps Remain for Unwary Taxpayers
February 29, 2012
The 2012 annual report on the tax refund anticipation loan (RAL) industry from the National Consumer Law Center and Consumer Federation of America.
- Letter to Bank Regulators: Stop Bank Payday Lending
February 22, 2012
Two hundred and fifty national, state and local organizations and individual advocates have asked bank regulators to stop banks from making predatory payday loans, which carry triple-digit annual interest rates of as much as 400 percent.