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Comment Letters

Our in-depth research of financial practices is intended to guide policymakers and opinion leaders working to improve the state of lending.
February 16, 2021
Comment to the Federal Reserve Board: Modernizing Community Reinvestment Act (CRA) Regulations
February 16, 2021
Comment: Proposed Change to NCUA Overdraft Policy, RIN 3133-AF20
January 4, 2021
Comment to OCC Opposing Proposed Rule to Pressure Banks to Support Predatory Lending
December 22, 2020
Comment on Opportun’s Bank Charter Application
December 14, 2020
Broad Opposition to the CFPB’s Plan to Engage in Payday Loan Disclosure Testing
December 14, 2020
Comment: CFPB Outline of Proposals Under Consideration and Alternatives Considered for Section 1071
December 1, 2020
Comment on Request for Information on the Equal Credit Opportunity Act and Regulation B
November 5, 2020
Comment: Urging the CDFI Fund to Establish Lending Standards for Certification or Renewal
November 5, 2020
Consumer, Civil Rights, and Housing Organizations Welcome the CDFI Fund's Focus on Community Development
October 13, 2020
Comment to the Federal Housing Finance Agency on 2021 Enterprise Housing Goals Proposed Rule
September 10, 2020
Comment: Current CDFI Designation is Not Sufficient to Ensure that Loans Will Be Affordable and Responsible.
September 9, 2020
Comment: Final Qualified Mortgage (QM) Rule Must Effectively Protect Consumers and Promote Access to Responsible Mortgage Credit
September 3, 2020
Comment: OCC Rule Would Allow Payday Lenders to Use Rent-a-Bank Schemes to Evade State Laws
August 31, 2020
Comment to the Federal Housing Finance Agency on Enterprise Regulatory Capital Framework
August 4, 2020
The CFPB’s Approach to Time-Barred Debt and the Proposed Disclosures Will Perpetuate Abusive Practices and Widen the Racial Wealth Gap
July 29, 2020
Additional Testing of the Validation Notice is a Necessary Part of the CFPB’s Debt Collection Rulemaking
July 2, 2020
Comments to FDIC on Notice of Proposed Rulemaking for Industrial Loan Companies
June 1, 2020
Comment on Consumer Financial Protection Bureau's RFI to Assist the Taskforce on Federal Consumer Financial Law Taskforce
May 15, 2020
Comment: The Paycheck Protection Program Continues To Be Disadvantageous to Smaller Businesses, Especially Businesses Owned by People of Color and the Self-Employed
May 4, 2020
Comment on the ED’s Proposed Distance Education Rule: As More Programs Move Online, Do Not Weaken Student Protections

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