On November 2, 2021, Marisabel Torres, director of California Policy, CRL testified before the House Task Force on Financial Technology. Her written testimony as well as her oral remarks are available for download. Watch the live hearing:
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.
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The CFPB should rescind the Bureau’s November 2020 EWA Advisory Opinion or to revise its unsound reasoning to prevent evasions of credit laws. The CFPB should also revisit the December 2020 Compliance Assistance Sandbox Approval Order regarding PayActiv for the same reason, and to order PayActiv to cease misusing the order. We also urge the Bureau to eliminate or significantly alter the “innovation” programs adopted in the last few years, which have resulted in a secretive, one-sided process for industry to seek exemptions from or skewed interpretations of critical consumer protection laws...
The National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending wrote to the CFPB to express serious concerns about two actions that the CFPB took a year ago under Director Kathy Kraninger finding that certain earned wage access (EWA) products are not “credit” under the Truth in Lending Act. These actions and the legal reasoning underlying them have the potential to open up huge loopholes in our lending and even fair lending laws. They urge the CFPB to regulate fee-based EWA products as credit. The CFPB should rescind or significantly revise the...
From the coalition letter to Michael J. Hsu, acting comptroller of the currency, Office of the Comptroller of the Currency: We the undersigned community, consumer, and civil rights organizations write to express serious concerns about Oportun’s application to the Office of the Comptroller of the Currency (OCC) for a national bank charter. Exactly one year ago, Oportun made headlines for grossly abusive debt collection practices, which is especially alarming given the company’s stated focus on serving Latino, immigrant, and low-to-moderate income borrowers. ProPublica and The Guardian published...
From the letter to Acting Director Shalanda Young, Office of Management and Budget We the undersigned civil rights and consumer advocacy organizations are writing in response to the Office of Management and Budget’s May 5, 2021, Request for Information on Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government. We applaud the OMB for seeking input on the critically-important topic of advancing equity in government. Our organizations believe that the responses below will help inform the OMB’s policies.
The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Request for Input on Climate and Natural Disaster Risk Management at the Regulated Entities. CRL is a nonprofit, non-partisan research and policy organization dedicated to protecting homeownership and family wealth by working to eliminate abusive financial practices. CRL is an affiliate of Self-Help, one of the nation’s largest nonprofit community development financial institutions. For over 40 years, Self-Help has...
The private bail bonds industry is woefully underregulated. Unlawful consumer credit arrangements and debt–collection practices abound, yet no government body is charged with addressing these aspects of bail bonds contracts. DFPI has the authority and the expertise to provide much-needed regulation in this industry and doing so would align with its mission. For the good of bail bonds consumers too often fleeced by unlawful financial products during a particularly stressful moment in their lives, we urge DFPI to recognize and use its authority under the CCFPL, the DCLA, and Cal. Fin. Code...
On September 25, 2020, Governor Newsom signed AB 1864 (Chapter 157, Statutes of 2020), establishing the California Consumer Financial Protection Law (“CCFPL”) under Division 24 of the Financial Code. The undersigned consumer advocates are encouraged to see that the Department of Financial Protection and Innovation (“DFPI” or the “Department”) is seeking input from stakeholders in developing regulations to implement the CCFPL. We write this comment in response to the following questions regarding registration requirements that the DFPI posed in 3(a)-(b): For what industries should the DFPI...
This set of comments will focus on earned wage access programs and other newer types of payday advance programs. NCLC and CRL have also joined a broader set of comments submitted by the California Economic Justice Coalition on a broader range of issues and a second set in conjunction with the Student Borrower Protection Center on income share agreements. These comments will focus in particular on these questions that DFPI poses: For what industries should DFPI first establish registration requirements under Financial Code section 90009(a)? What are the consumer protection risks posed by those...
Our broad coalition of consumer and business organizations thanks you for the opportunity to comment regarding how the DFPI can best implement AB 1864 (Limón), the California Consumer Financial Protection Law (CCFPL). The CCFPL is an important and significant step forward for California and offers the promise of a bold consumer-facing department that can be at the forefront of consumer protection. We look forward to partnering with you and your team to help make that promise a reality. We must first acknowledge that the on-going COVID-19 pandemic has exacerbated disparities for low and...