Comment Letter

The market for personal loans is massive and growing, yet the fintechs and other non-bank lenders who make such loans are not subject to regular oversight by the Consumer Financial Protection Bureau (CFPB), which has “created an unlevel playing field and a large risk to consumers,” write the Consumer Bankers Association (CBA) and the Center for Responsible Lending (CRL). The groups jointly filed a petition for the CFPB to develop a rule that would define larger participants in the market for personal loans so that sizable non-depository lenders would be subject to consistent CFPB supervision...

Amid growing concern about corporate consolidation, the Center for Responsible Lending (CRL) and Americans for Financial Reform Education Fund are leading a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank. Their comment letter points to several reasons why regulators should deny the application, including TD Bank’s exceptionally poor treatment of consumers and an exacerbation of the “too-big-to-fail” problem if the merger is approved. Co-signatories are Alaska PIRG, American...

The Center for Responsible Lending and Center for Community Self-Help applaud the effort of the Agencies to update and modernize the CRA regulations given the massive changes that have taken place in the financial services industry in the more than 25 years since the regulations were last amended. Likewise, we support the overall thrust of the Agencies’ proposal, which provides a much more robust, transparent, and objective framework for conducting CRA evaluations than that provided by current regulations. We offer these comments to respond to some of the questions posed by the NPRM and...

The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, NAACP, National Coalition for Asian Pacific American Community Development, National Fair Housing Alliance, and National Urban League file this comment in response to Fannie Mae's and Freddie Mac's (the Enterprises) proposed Underserved Markets Plans. Thank you for the opportunity to provide input on the Enterprises’ plans. The content of the proposed plans is critical to determining whether the Enterprises are fulfilling their Duty to Serve obligations in each underserved market – manufactured housing...

The Center for Responsible Lending and the undersigned consumer, civil rights, and community organizations would like to thank you for the opportunity to submit comments on the Federal Housing Finance Agency’s (FHFA) proposed rule setting the 2018-2020 Affordable Housing Goals for Fannie Mae and Freddie Mac (“Enterprises”). We appreciate FHFA’s efforts to improve strategies to ensure those from lower wealth communities have access to the market and homeownership. While we support the FHFA’s efforts, we believe that the tests proposed would set unnecessarily low goal standards and would not be...

Deregulatory measures are not the antidote to the affordable housing crisis in our nation. The government must provide the necessary investments to combat the crisis and ensure that potential regulatory changes enhance equity, not detract from it. HUD and the White House Council must not use the RFI process to undermine important public interest protections, such as civil rights, labor, environmental, and public health.

NALCAB, the National Association for Latino Community Asset Builders, The National Coalition for Asian Pacific American Community Development (CAPACD), and the Center for Responsible Lending (CRL) write in response to the invitation for public comments regarding changes made to the Community Advantage Pilot Program (CA) noticed in the Federal Register on April 29th, 2022. Access to capital is one of the greatest barriers to success for minority entrepreneurs. Since its inception in 2011 CA has successfully expanded access to capital for small businesses located in underserved communities...

CRL urges FHFA to provide for a streamlined approval process for the GSEs to submit new activities that do not rise to the level of a new product. Otherwise, given the proposed rule’s extraordinarily broad definition of a new activity, the GSEs will be stymied from pursuing new endeavors by excessive red tape and overly burdensome documentation requirements. A streamlined process is particularly important to encourage innovation in creating additional affordable housing activities and pilots, as well as offer new loss mitigation options for borrowers in a time of crisis such as the COVID‐19...

From the introduction to the comment: Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low income clients), Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of Transportation Alliance Bank (dba TAB Bank). TAB Bank serves as a rent-a-bank, nominally originating predatory loans at rates up to 189% APR for Duvera Billing Services, dba EasyPay Finance, to help EasyPay evade state...

The Center for Responsible Lending (CRL), along with Americans for Financial Reform (AFR), Consumer Federation of America (CFA), the National Community Reinvestment Coalition (NCRC), and National Consumer Law Center (NCLC) (on behalf of its low-income clients) submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to their call for public input on how to save Americans billions in junk fees charged by financial companies, leading consumer advocacy organizations submitted an extensive comment letter detailing junk fees across a wide range of consumer financial...