Consumer Finance

The Federal Deposit Insurance Corporation's (FDIC) proposed guidance provides a framework that will require banks to place more stringent requirements on the institutions that they conduct business with. However, as written, the proposed guidance will still enable consumer harm and allow FDIC-supervised institutions to engage in risky relationships with third parties via rent-a-bank lending. We are deeply concerned about the risk this could create for the Federal Deposit Insurance fund, the reputation of FDIC-insured banks, and the FDIC itself, as well as the adverse impact on consumers.

The undersigned Center for Responsible Lending (CRL) and National Consumer Law Center, on behalf of its low income clients (NCLC), write to comment on the update to the Uniform Interagency Consumer Compliance Rating System (CC Rating System) by highlighting three areas of particular concern: Overdraft practices Loans with a total cost of credit exceeding 36% annual percentage rate (APR) Bank partnerships with non-bank lenders whereby non-banks make loans they could not independently make under state law – i.e., rent-a-bank schemes The CC Rating System is right to emphasize harm to consumers...

The Financial CHOICE Act attacks the CFPB's structure and authority and would frustrate the CFPB's ability to fulfill its mission. Title III of the bill is aimed at obstructing the CFPB's ability to protect consumers from predatory financial products and practices. This title severely weakens the CFPB’s structure and authority in the following ways: Changes the structure of the CFPB from its current, effective single-director structure to a less effective five-member commission; Eliminates independent funding of the CFPB, putting it at the mercy of an annual appropriations process and...

CRL strongly supports the CFPB’s proposed rule to limit pre-dispute mandatory (forced) arbitration clauses in consumer finance contracts. Forced arbitration is a widespread issue affecting a plethora of financial products and services; it impacts the consumers CRL advocates for and implicates CRL’s mission to eliminate abusive financial practices. CRL applauds the CFPB for its efforts to restore consumers’ ability to band together to protect their rights in class actions as well as increase transparency in the use of forced arbitration in individual cases. Although the proposed rule is strong...

A better enforced and strengthened CRA would be a critical tool in ensuring that underserved communities across the country are provided with the credit opportunities needed to better recover from the 2008 financial crisis. While more affluent neighborhoods have bounced back or have begun to bounce back following the crisis, many low- and moderate-income neighborhoods continue to struggle eight years later with fewer mortgages and small business lending opportunities.

This memo summarizes the findings from a statewide poll of 501 likely 2016 general election voters in Colorado. Only those registered voters who had participated in a past general election were invited to participate, as well as any new registrants since the November 2012 election. View the polling questions and topline results. (PDF)

This letter signed by CRL along with 163 other organizations urges the CFPB to use its Congressional authority to restrict forced arbitration. Lenders and other financial services companies use forced arbitration to push consumers out of court and into a private arbitration system that they tilt to favor large financial interests. The CFPB’s empirical findings in its comprehensive and evidence-based report on the use of arbitration clauses unequivocally demonstrate that forced arbitration imposes conditions that restrict consumers’ rights and block their access to courts, giving lenders an...

This letter urges the opposition of HR 1261 or any similar bills that undermine the independence of the Consumer Financial Protection Bureau (CFPB) by subjecting it to the appropriations process. It is less than five years since the CFPB was established. Since then, it has fulfilled Congress's vision of a federal agency with "the authority and accountability to ensure that existing consumer protection laws and regulations are comprehensive, fair, and vigorously enforced." Through its rulemaking, supervision, enforcement, and consumer education and complaint system, the CFPB has made enormous...

In a new report, the Center for Responsible Lending – along with Americans for Financial Reform – examines the impact of advocacy efforts of policy and regulation. The report take stock of both gains (actions that support or defend consumer protections) and losses (actions that jeopardize or reduce consumer protections) – specifically in the following areas: Federal legislation State legislation Federal regulatory actions Federal judicial actions State regulatory actions State judicial actions Industry practices In addition, the report takes stock of efforts that have yet to yield specific...

The consumer groups signing this letter oppose the Taking Account of Institutions with Low Operation Risk Act of 2015 (H.R. 2896) and amendments that will put consumers at risk from dangerous products or practices and undermine the established notice and comment process in place for financial regulations. If adopted, the TAILOR Act could allow financial institutions to justify and exploit potentially dangerous loopholes, create confusion in the marketplace and cause unnecessary delays in the adoption of important consumer protections. Prudential and consumer regulators already have broad...