Comment Letter

CRL's comment to the Small Business Administration on the April 15 Interim Final Rule implementing the Paycheck Protection Program focuses on two key challenges with the PPP to date: The Paycheck Protection Program continues to be disadvantageous to smaller businesses, and businesses without employees. PPP loans can be forgiven if the business is able to use the funds for eligible expenses within eight weeks of receiving the loan. This requirement makes it challenging, particularly for very small businesses, to ensure loans are forgiven rather than converted into long-term debt. The PPP fee...

From the full comment letter: As more borrowers than ever migrate to online platforms, the Department’s role in ensuring program integrity is even more vital. The consensus language in the NPRM represents the best compromise between industry, innovators, and borrowers. If it is changed at all, it should be strengthened, not weakened. The final rule should include the consensus definitions regarding regular and substantive interactions, retain the consensus agreement to limit the portion of a program that may be outsourced to 50% (with accreditor approval required above 25%), and prohibit...

From the full comment letter: The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) strongly oppose the OCC and FDIC’s proposed Community Reinvestment Act (CRA) regulations.... The most troubling outcome of theproposed rule is that it would unwittingly sanction redlining. The proposal relies on an overly simplistic evaluation measurethat focuses on the total dollar value of CRA qualifying activity.We strongly oppose this approach, which we believe would fail to hold banks accountable for meeting the convenience and needs of all of their communities, as...

From the letter: We believe such a rulemaking is necessary to provide much-needed clarity to this thus-far opaque part of the U.S. financial system – that is, the manner in which parent companies and affiliates of ILCs are subject to any kind of federal regulatory or supervisory oversight. By contrast, the federal statutory, regulatory and supervisory framework for parent companies and affiliates of ordinary banks is fully transparent and quite clear. We congratulate you and the FDIC staff for doing this important work, and for soliciting public comment on it.

First, we note that the affordable housing goals are part of the FHFA’s clearly laid out mission to reach underserved communities and that increasing access to mortgage credit in these communities is essential to the housing recovery. Second, we recommend that the FHFA maintain the two-part test, and strongly urge that the FHFA set a higher benchmark standard and require that both standards be matched or surpassed. Third, we contend that how FHFA addresses findings of failure to meet a metric is critical and recommend the FHFA act more assertively to enforce procedures in the Housing and...

The undersigned community, consumer, civil rights, faith and small business organizations write to strongly oppose the FDIC’s proposed rule on “federal interest rates,” which threatens to eviscerate state interest rate limits around the country and encourage the spread of predatory lending. Download the letter to continue reading. (PDF)

These comments are submitted on behalf of the National Fair Housing Alliance (NFHA) and the Center for Responsible Lending (CRL) to express our organization’s strong support for effective enforcement of the Community Reinvestment Act, and our concern about the approach proposed by the OCC in the above-referenced Federal Register notice, dated September 5, 2018, entitled “Reforming the Community Reinvestment Act Regulatory Framework.” The Community Reinvestment Act is a critical component of efforts to stop lending discrimination throughout the nation and the National Fair Housing Alliance...

We, the consumer and civil rights groups named above, write to strongly oppose the Federal Deposit Insurance Corporation (FDIC)’s proposed rule on Federal Interest Rate Authority (proposal or proposed rule). The proposed rule would allow predatory non-bank lenders to route their loans through banks to evade state interest rate caps. The proposal is outside the FDIC’s statutory authority; it is not justified by any evidence of problematic impact on legitimate bank operations; and the FDIC has failed to consider the strong likelihood that the proposal will unleash a torrent of predatory lending...

From the letter: Interest rate limits are the single most effective tool states have to protect their residents from predatory loans. Predatory loans include payday and car title loans that often carry annual interest rates as high as 300% or more. Predatory loans also include high-cost installment loans and lines of credit with rates approaching and well exceeding 100%. These loans target financially distressed individuals, compound their debt burden, and leave them worse off. Payday lenders also disproportionately prey on communities of color, stripping them of income, exacerbating financial...

The Center for Responsible Lending and the National Consumer Law Center (on behalf of its low income clients), as part of a coalition of consumer and civil rights groups wrote the comment letter included on this page, which details the groups' strong opposition to a proposed rule from the Office of the Comptroller of the Currency (OCC)’. The proposed rule would allow predatory non-bank lenders to launder their loans through banks to evade state interest rate caps. The proposal is outside the OCC’s statutory authority; it is not justified by any evidence of problematic impact on legitimate bank...