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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Oppose H.R. 998 Searching for and Cutting Regulations that are Unnecessarily Burdensome Act of 2017 (SCRUB Act)

Oppose H.R. 998 Searching for and Cutting Regulations that are Unnecessarily Burdensome Act of 2017 (SCRUB Act)

H.R. 998 would establish a new bureaucracy empowered to dismantle long-established science-based public health and safety standards and would make it significantly more difficult for Congress and federal agencies to implement essential future protections. Along with previous bills that have passed the House and the President’s Executive Orders instituting a regulatory freeze and requiring the removal of two rules for...
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Letters to Congress
Consumer Finance

Letter to the Comptroller of the Currency: Innovation Should Not Come at the Expense of Consumer Protection

Letter to the Comptroller of the Currency: Innovation Should Not Come at the Expense of Consumer Protection

The Center for Responsible Lending (CRL), The Leadership Conference on Civil and Human Rights, and the NAACP have sent a letter to Comptroller of the Currency Thomas J. Curry urging him not to offer national charters to financial technology firms, which could severely undermine state oversight and state laws that protect consumers and small business owners from abusive financial products...
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Letters to Congress
Consumer Finance

Strong Opposition to Enabling Lenders to Avoid State Protections and Oversight

Strong Opposition to Enabling Lenders to Avoid State Protections and Oversight

Over 250 consumer, civil rights, and community groups wrote this letter to the Office of the Comptroller of the Currency to express strong opposition to the proposed new federal nonbank lending charters that would enable lenders to avoid state interest rate caps, other state protections, and state oversight. State laws often operate as the primary line of defense for consumers...
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Letters to Congress
Consumer Finance

Strong Opposition to New Federal Nonbank Lending Charters

Strong Opposition to New Federal Nonbank Lending Charters

The 49 consumer, civil rights, small business, and other community organizations signed on to this letter to express strong opposition to new federal nonbank lending charters that would enable chartered entities to avoid state interest rate caps, other state consumer protection laws, and state oversight, putting consumers and small businesses at risk. The Office of the Comptroller of the Currency...
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Letters to Congress
Consumer Finance

Comment on FDIC Seeking Comment on Proposed Guidance for Third-Party Lending

Comment on FDIC Seeking Comment on Proposed Guidance for Third-Party Lending

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...
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Comment Letter
Consumer Finance

Threats to Consumers in the Update to the Uniform Interagency Consumer Compliance Rating System

Threats to Consumers in the Update to the Uniform Interagency Consumer Compliance Rating System

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...
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Comment Letter
Consumer Finance

Do Not Undercut the Essential Reforms of Dodd-Frank: Oppose the Financial CHOICE Act

Do Not Undercut the Essential Reforms of Dodd-Frank: Oppose the Financial CHOICE Act

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...
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Comment Letter
Consumer Finance

Strong Support for the Proposed Rule to Limit Pre-dispute Mandatory Arbitration Clauses in Consumer Finance Contracts

Strong Support for the Proposed Rule to Limit Pre-dispute Mandatory Arbitration Clauses in Consumer Finance Contracts

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...
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Comment Letter
Consumer Finance

Enforce the Community Reinvestment Act

Enforce the Community Reinvestment Act

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...
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Letters to Congress
Consumer Finance

Colorado Voters Strongly Opposed to Raising the Maximum Interest Rate on Consumer Loans

Colorado Voters Strongly Opposed to Raising the Maximum Interest Rate on Consumer Loans

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)
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Research
Consumer Finance Payday and Other Small Dollar Loans
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