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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.
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 Aproach 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 to the Small Business Administration: 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
April 8, 2020
Strong Opposition to the OCC and FDIC’s Proposed Community Reinvestment Act (CRA) Regulations
March 15, 2020
Deposit Insurance Applications by Industrial Banks and Industrial Loan Companies
February 5, 2020
Comment Opposing the FDIC’s Proposed Rule That Would Allow Predatory Non-bank Lenders to Route Their Loans Through Banks
February 4, 2020
Letter to the FDIC Opposing the Evisceration of State Interest Rate Limits Around the Country
January 21, 2020
Community, Consumer, Civil Rights, and Faith Groups Strongly Oppose OCC's Proposed Rule on State Interest Rate Limits
January 21, 2020
OCC Rent A Bank Rule Proposal Comment Letter 2020
October 18, 2019
Comment: Faith Leaders on HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard
October 18, 2019
Comment: HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard
September 19, 2019
Debt Collection Rule Should Not Perpetuate Abusive Practices And Widen The Racial Wealth Gap
September 19, 2019
Strengthen The Proposed Debt Collection Rule To Fulfill The CFPB’s Obligation To Faithfully Implement The Fair Debt Collection Practices Act (FDCPA)

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