CRL submitted comments to Acting Director Vought arguing the draft Strategic Plan retreats from the Bureau's statutory obligations at a moment of acute consumer affordability pressure, raising 3 core concerns: Fair banking is defined too narrowly. Objective 1.1 centers almost entirely on ideological debanking under EO 14331, with no mention of ECOA, fair lending, or the racial wealth gap. Objective...
This proposed rule is the OCC’s initial attempt at implementing a regulatory framework under the GENIUS Act for payment of stablecoin activities. CRL answered question 43 recommending that at account opening and on monthly statements there is a plain language disclosure informing consumers that these accounts are not insured by the FDIC. CRL also joined Americans for Financial Reform on...
CRL opposes the implementation of this proposed rule and any changes to HUD’s current eligibility status. The proposed rule will result in mixed-status families not been able to live as a family unit in subsidized housing. CRL put forth the following arguments in support of its position: The plain text of 42 U.S.C. §1436a(b)(2) and §1436a(c)(1)(A) demonstrates that Congress intended...
CRL highlights the harms consumers face in the District of Columbia, which are similar to those associated with storefront payday loans. CRL offers its recommendations to the District of Columbia to consider as it moves forward with investigating and addressing payday loan apps. We recommend developing guidance to affirm the status of payday loan apps as credit under existing law...
CRL responded to the Federal Reserve Board regarding the Enova/Grasshopper merger, requesting the application for a bank holding company to be denied, or in the alternative, additional time of up to 60 days to comment, and to hold public hearings. This request is based on Enova’s record of high-cost lending of products that have interest rates over 100% and a...
The purpose of this letter is to complement the National Fair Housing Alliance’s comment letter that CRL is a signatory on by focusing on the procedural deficiencies of the cost analysis section of the Notice of Proposed Rulemaking. Specifically, the comment letter highlights that none of the requisite requirements under the Regulatory Flexibility Act, Executive Order 12866, or § 1022(b)(2)...
The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, the League of United Latin American Citizens (LULAC), Legal Defense Fund, and National CAPACD - National Coalition for Asian Pacific American Community Development submitted a comment letter yesterday to the Consumer Financial Protection Bureau that opposes the CFPB’s Notice of Proposed Rulemaking (NPRM) that would delay and...
The Center for Responsible Lending agrees with the Federal Housing Finance Agency on the importance of acting intentionally and swiftly to positively address this nation’s housing challenges but believe that the proposed rule will not have the desired effect. Specifically: by reducing the low-income purchase goal by 4 percentage points (25% to 21%) for the next three years, nearly cutting...
CRL's comment argues against the proposed rule to limit the Bureau’s supervisory jurisdiction over non-depository institutions by interpreting the phrase “risk to consumers” in the Consumer Financial Protection Act to mean “a high likelihood of significant harm.” In the comment, CRL argues that the Bureau’s proposed interpretation conflicts with the plain meaning of the statute’s words, the statutory context provided...
The Center for Responsible Lending writes this comment to emphasize how the proposed rule’s vague and ambiguous standards would undermine program integrity, create a dangerous precedent for future administrations, and harm borrowers and the communities they serve.