A broad coalition of consumer groups filed comments supporting the CDFI Fund’s changes to the application for CDFI certification. In recent years, many harmful financial products have been pushed on underserved communities in the name of “access to credit” and “financial inclusion.” Most CDFIs stay away from these harmful products and are true to their mission but far too many entities have obtained CDFI status despite engaging in these irresponsible financial practices. The coalition supports the Fund’s changes to the CDFI application to close many loopholes that allowed CDFIs to offer...
Home ownership has been the primary means for most American families to build and pass on inter-generational wealth. However, government-sanctioned racial discrimination in housing and mortgage finance markets robbed many families of this opportunity, and today’s racial homeownership gap is barely changed from the levels of more than 50 years ago. Closing the homeownership gap is essential to closing the racial wealth gap. Additionally, predatory mortgage lending practices drained trillions in wealth from families, especially Black, Latino, low wealth and low-income Americans. CRL successfully advocated for the Dodd-Frank Wall Street Reform and Consumer Protection Act, which has made the mortgage market far safer for consumers. CRL is building on this progress by working to ensure that all credit-worthy borrowers have access to fair, affordable, and sustainable mortgages. And that policy makers and market participants develop solutions that are appropriate to respond to the scale of this housing crisis.
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The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund strongly support the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. In November 2020, CRL and Self-Help urged the Fund to adopt several critical consumer protections in the Fund’s certification application. We are very pleased to see that the Fund has proposed to adopt many of those protections, including: Limiting the ability of CDFIs to lend at interest rates that exceed 36% Requiring CDFIs to lend...
As of the end of August 2022, 350,000 FHA borrowers were seriously delinquent. Some of these borrowers will regain their financial footing, cure their delinquency, and resume their monthly payments, while others will sell their homes. The remainder will need a reduction in their monthly payment to an affordable level to remain in their home. However, the combination of the mechanics of an FHA modification and a substantial rise in the mortgage rate has made modifications ineffective at delivering payment reduction. To modify an FHA loan, the loan must be purchased out of the mortgage-backed...
The National Consumer Law Center (on behalf of its low-income clients), the Center for Responsible Lending, and the National Housing Law Project submitted this comment to the Consumer Financial Protection Bureau in response to a request for information regarding mortgage refinances and forbearances.
The Center for Responsible Lending and Center for Community Self-Help applaud the effort of the Agencies to update and modernize the CRA regulations given the massive changes that have taken place in the financial services industry in the more than 25 years since the regulations were last amended. Likewise, we support the overall thrust of the Agencies’ proposal, which provides a much more robust, transparent, and objective framework for conducting CRA evaluations than that provided by current regulations. We offer these comments to respond to some of the questions posed by the NPRM and...
While most homeowners with GSE-backed mortgages have recovered from pandemic-related hardships and reinstated their mortgage, as of June 7, about 1.6% of outstanding GSE borrowers were in a state of nonpayment: about 140,000 GSE-backed loans were in COVID-19 Forbearance, and another roughly 300,000 loans were delinquent outside of forbearance. For those GSE borrowers who were less than 2 months delinquent as of the onset of the pandemic who cannot resume their originally scheduled monthly payments due to ongoing pandemic-related financial hardship, the GSEs offer the COVID-19 Flex Modification...
On June 29, 2022, Mike Calhoun, CRL's president, testified before the House Committee on Financial Services for a hearing entitle, “Boom and Bust: Inequality, Homeownership, and the Long-Term Impacts of the Hot Housing Market.” His written testimony is available for download. Watch a recording of the hearing:
Many FHA borrowers took advantage of record-low interest rates during the COVI9-19 pandemic and refinanced their mortgage. However, as of November 2021, there were over 4 million FHA borrowers who could realize a substantial reduction in their monthly payments by refinancing but had not done so. The average borrower in this cohort would save $229 per month ($2,750 per year) by refinancing their mortgage. Low-to-moderate income (LMI), Black, and Hispanic households had slower refinancing rates compared to higher income, White, and Asian households during the pandemic-induced refinancing wave...
Two vital elements of social and economic mobility are to increase the homeownership rate by enabling more non-homeowners to become first-time homebuyers and reduce the racial disparities in homeownership rates caused in large part by deliberate discriminatory policies and practices. The Government Sponsored Enterprises (GSEs) have the ability to improve both through their affordable housing goals and lending programs. The National Fair Housing Alliance (NFHA) and Center for Responsible Lending (CRL) believe that the Federal Housing Finance Agency (FHFA) should expand the eligibility of the...