Consumer Finance

CRL monitors developments across the consumer finance sector and acts to protect people’s pocketbooks from financial misconduct so families can build financial stability. This includes advocating for enforcement of laws banning discrimination based on race, national origin, sex, and other protected characteristics. CRL also fights to defend the Consumer Financial Protection Bureau, a crucial government watchdog that was established in the wake of the 2008 Financial Crisis to stop predatory practices. We support the development of policy and regulatory infrastructure needed to ensure an equitable green lending marketplace for all consumers. 

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Strong Bipartisan Support for Ensuring “Earned Wage Access” Apps Comply With Existing Consumer Protections, Including Interest Rate Caps

Strong Bipartisan Support for Ensuring “Earned Wage Access” Apps Comply With Existing Consumer Protections, Including Interest Rate Caps

The newest poll from the bipartisan polling team Lake Research Partners and Chesapeake Beach Consultingi provides fresh evidence that the overwhelming majority of Americans across the political spectrum support regulating the financial industry and protecting consumers, including requiring smartphone app-based payday lenders, which call their product “Earned Wage Access” (EWA) products, to comply with a 36% Annual Percentage Rate (APR)...
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Research
Consumer Finance

Comment on OCC Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act

Comment on OCC Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act

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...
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Comment Letter
Consumer Finance

CFPB’s Strategic Plan Falls Short, CRL Highlights Serious Deficiencies That Will Hurt Consumers

CFPB’s Strategic Plan Falls Short, CRL Highlights Serious Deficiencies That Will Hurt Consumers

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...
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Comment Letter
Consumer Finance Payday and Other Small Dollar Loans

Comment on Equal Credit Opportunity Act - Regulation B

Comment on Equal Credit Opportunity Act - Regulation B

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)...
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Comment Letter
Consumer Finance

CRL and National Civil Rights Groups Oppose CFPB Proposal to Weaken Small Business Lending Transparency Rule 

CRL and National Civil Rights Groups Oppose CFPB Proposal to Weaken Small Business Lending Transparency Rule 

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...
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Comment Letter
Consumer Finance

CRL Signs Amicus Brief Supporting a Politically Independent FTC

CRL Signs Amicus Brief Supporting a Politically Independent FTC

CRL signed onto an amicus brief along with 39 other organizations to support a credible, politically independent and bipartisan FTC commission. The brief urges the Court to reaffirm Humphrey’s Executor 295 U.S. 602 (1935) and the for-cause requirement for terminations for the FTC and certain other governmental entities. The brief provides a number of specific examples of the importance of...
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Amicus Brief
Consumer Finance

Amicus Brief In Support of NTEU’s Request for En Banc Review at the US Court of Appeals for the DC Circuit

Amicus Brief In Support of NTEU’s Request for En Banc Review at the US Court of Appeals for the DC Circuit

CRL signed onto an amicus brief supporting NTEU’s request for en banc review at the US Court of Appeals for the DC Circuit. NTEU requests the full court to review a decision that vacates a preliminary injunction in the lower case, which would allow the administration to reduce CFPB’s funding and fire its staff. This is the second amicus brief...
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Amicus Brief
Consumer Finance
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