Research & Policy

CRL Senior Research Debbie Bocian covers the key findings in the "Mortgages" chapter of State of Lending. </p>

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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.

Center for Responsible lending joined with Financial Services Roundtable and Housing Policy Council to ask Congress to extend the Mortgage Forgiveness Debt Relief Act. This tax law has bi-partisan support and is critical to helping homeowners and communities struggling with the ongoing foreclosure crisis. Read the letter sent to the Senate Committee on Finance Read the letter to the House Ways and Mean Committee

Wells Fargo's direct engagement in payday lending should have a significant negative impact on their upcoming Community Reinvestment Act evaluation.

The CaliforniaForeclosure Reduction Act – SB 900 (Leno, Corbett, DeSaulnier, Evans, Pavley, Steinberg) & AB 278 (Eng, Feuer, Mitchell) extends key protections of the National Mortgage Settlement to all mortgage servicers for owner-occupant borrowers at risk of foreclosure. Scope of Coverage What Loans? Limits covered loans to first liens of owner-occupied, one-to-four unit principal residence mortgages. Which Servicers? All servicers: General obligations, including prohibiting dual tracking and prohibition on false documents applies to all servicers. Small servicers: Servicers that foreclose...

Foreclosures have drained nearly $2 trillion dollars in lost property value from nearby households. Half of this spillover cost has been incurred by communities of color. People who happen to live near foreclosures lose significant home equity. $1.95 trillion in property value has been lost or will be lost by residents who live close to foreclosed properties. Based on loans that entered foreclosure between 2007 and 2011. This spillover estimate includes losses stemming from completed foreclosures and also future losses projected on foreclosure starts. Communities of color are bearing the...

In this comment, 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.

The ongoing foreclosure crisis has made plain the need for meaningful mortgage servicing standards that apply to mortgages and servicers across the country. Both policymakers and homeowners alike are now familiar with a range of mortgage servicing shortcomings that have made it difficult for borrowers to obtain loan modifications and other loss mitigation options. Consumer protection for servicing is particularly important because, even though borrowers can choose their lender, they cannot controlwho services their loan. One of the challenges raised by borrowers and advocates has been the...

Five years into the foreclosure crisis, borrowers across the country are still struggling with their mortgage payments, and many seek housing counseling to help manage their finances and guide them through the loan modification process. Between 2008 and 2012, the National Foreclosure Mitigation Counseling Program provided foreclosure counseling to nearly 1.4 million homeowners and mortgage-related legal assistance to more than 37,000 homeowners. This analysis helps identify which metropolitan and rural areas have been hardest hit by the foreclosure crisis and remain areas of greatest need for...

Homeville.us By joining Homeville and tweeting, you're standing up for the mortgages we need now. Fair loans that serve all creditworthy borrowers. Designed to last. Recovering the American Dream After years of steady progress, the homeownership rate in America has seen its biggest drop since the Great Depression. Lax lending rules and Wall Street's lust for bad mortgages triggered a financial crisis that unraveled previous ownership gains and pushed economic security even further out of reach for millions of Americans. Today we have an opportunity to return to a stable lending environment...

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.

Finding the Right Balance Lack of underwriting, not low down payments, caused the current crisis. Strong underwriting is the best way to rein in risky loans—and Dodd-Frank already requires this. As part of implementing the Dodd-Frank financial reform bill, federal regulators are charged with defining a "Qualified Residential Mortgage" or QRM. Government proposals have called for down payments up to 20% on QRM loans, but new research shows that mandating large down payments would be a mistake for business and consumers. Analyzing nearly 20 million mortgages made between 2000 and 2008, the...

Many families who can pay their mortgages on time don't have wealth reserves for a large down payment. 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—slowing housing recovery and dragging down the economy when we most need healthy growth. With a 10% Down Payment Lower and middle-income families who could be successful homeowners would be locked out of the lower-cost, mainstream housing market. Existing wealth disparities would get even worse. Given median housing...

Honorable Ben S. Bernanke Chairman Board of Governors of the Federal Reserve System Washington, DC 20551 Honorable Timothy Geithner Secretary U.S. Department of the Treasury Washington, DC 20220 Honorable Thomas J. Curry Comptroller Office of the Comptroller of the Currency Washington, DC 20219 Honorable Martin J. Gruenberg Acting Chairman Federal Deposit Insurance Corporation Washington, DC 20429 Mr. Edward DeMarco Acting Director Federal Housing Finance Agency Washington, DC 20552 Honorable Mary L. Shapiro Chairman Securities and Exchange Commission Washington, DC 20549 Honorable Shaun L. S...

Read the complete issue brief Read a short summary. Read the letter to regulators from CRL and six other organizations. Federal regulators are currently debating how to define "Qualified Residential Mortgages" (QRMs), a category of home loans established by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Under Dodd-Frank, mortgage lenders that sell their loans into the private secondary market must retain a portion of the loan's risk unless the loan is designated as a QRM. Because lenders are strongly motivated to avoid future costs on loans they originate, the QRM...

At the root of HR 6139 and similar legislation is an effort by non-bank lenders to circumvent new federal oversight and undermine consumer protections recently provided under recent Wall Street reforms. HR 6139 will needlessly move federal jurisdiction over non-bank financial service providers from the newly created Consumer Financial Protection Bureau (CFPB) to the Office of the Comptroller of the Currency (OCC), thus negating recent efforts to rein in reckless and abusive practices like those that ignited the current economic crisis. If HR 6139 or similar legislation is approved, non-bank...

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.

Bringing the "unbanked" into mainstream banking is good policy only if new account holders are not subject to financial practices that strip funds from these new accounts. Unfortunately, today's mainstream banking environment is fraught with danger for families who do not have a significant cushion of cash at their disposal. Local, state and federal agencies; civic organizations; and financial institutions are partnering in bringing these families into the mainstream. These stakeholders should ensure that programs promoting mainstream banking do not unintentionally create a supply of customers...

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.

Testimony of Kenneth W. Edwards Vice President of Federal Affairs, Center for Responsible Lending, before the House of Representatives Committee on Financial Services Subcommittee on Financial Institutions and Consumer Credit in regards to hearing on Examining Consumer Credit Access Concerns. The testimony emphasized three points: H.R. 6139 and similar legislation would circumvent the carefully contemplated supervisory, enforcement, and rulemaking authority of the Consumer Financial Protection Bureau (CFPB or Bureau) over certain non-depository financial institutions. The Dodd-Frank Wall...

Lack of regulation led to the foreclosure crisis that has destabilized the housing market and mortgage lending: Federal regulators could have stepped in to curb abusive lending practices in the years leading up to the foreclosure crisis, but this failed to happen. Instead, the private label securitization system bypassed government oversight by bundling an increasing number of subprime and Alt-A mortgages into mortgage-backed securities, and the widespread failure of these mortgages precipitated the still ongoing foreclosure crisis. Dodd-Frank, and the creation of the CFPB, are important...

Prepaid cards are an important new financial product that holds the promise of expanding access to modern electronic transactions to millions of consumers. However, prepaid cards lack consumer protections and some have features that expose consumers to unnecessary dangers. The most important step that the CFPB can take to ensure that prepaid cards fulfill their promise, and to prevent unfair, deceptive or abusive practices, is to ensure that prepaid cards are true to their essence as a prepaid transaction product. Overdraft and credit features must be prohibited on prepaid cards.

74% of Americans favor the CFPB Voters are nearly unanimous in their support for specific policies the CFPB has created A July 2012 poll demonstrates very broad bipartisan support for the Consumer Financial Protection Bureau (CFPB) and other reforms in the Dodd-Frank Wall Street Reform and Consumer Protection Act. This poll--taken at the two-year anniversary of Dodd-Frank--has similar results to a poll taken last year and shows continued strong voter support for the law's provisions and actions taken to date by the CFPB. Read CRL's analysis. Some key findings from the poll: A large majority of...

Read the Executive Summary This report by Pew's Safe Small-Dollar Loans Research Project—the first in Pew's Payday Lending in America series—answers major questions about who borrowers are demographically; how people borrow; how much they spend; why they use payday loans; what other options they have; and whether state regulations reduce borrowing or simply drive borrowers online. Pew: Who Borrows, Where They Borrow, and Why </p>