CRL urges FHFA to provide for a streamlined approval process for the GSEs to submit new activities that do not rise to the level of a new product. Otherwise, given the proposed rule’s extraordinarily broad definition of a new activity, the GSEs will be stymied from pursuing new endeavors by excessive red tape and overly burdensome documentation requirements. A streamlined process is particularly important to encourage innovation in creating additional affordable housing activities and pilots, as well as offer new loss mitigation options for borrowers in a time of crisis such as the COVID‐19...
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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Our comment discusses ECOA’s purpose, the importance of disparate impact theory, issues around artificial intelligence and machine learning models, special purpose credit programs, preemption, and small business lending. Additionally, CRL signed on to a detailed letter from the Americans for Financial Reform (AFR) Language Access Taskforce regarding the challenges in serving limited English proficient consumers.
The undersigned consumer, civil rights, and housing organizations welcome the CDFI Fund (Fund)’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. CDFIs are uniquely suited to promote community development and expand financial inclusion. At times, however, we see CDFIs use “financial inclusion” as the central purported justification for permitting irresponsible lending practices, unreasonably high interest rates, and erosion of longstanding consumer protections. Download the full comment to continue reading.
The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund welcome the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. To that end, we urge the Fund to establish lending standards that function as clear, bright-line eligibility requirements for CDFI certification or renewal: A fee-inclusive annual percentage rate (APR) limit of 36%, computed consistent with the current Military Lending Act regulations (or lower if required by state law);1 and For any mortgages...
From the introduction to the comment to the Federal Housing Finance Agency: On behalf of the undersigned consumer, civil rights, and housing organizations, we would like to thank you for the opportunity to comment on the affordable housing goals for Fannie Mae and Freddie Mac (the GSEs). In exchange for government support, the GSEs have an explicit public interest mission. This mission is foundational and part of their charters – the GSEs’ very reason for existing. The mission includes promoting access to mortgage credit to underserved borrowers, serving a countercyclical role in the mortgage...
From the full comment : Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB’s) qualified mortgage (QM) proposed rule. Given CFPB’s decision to end the GSE patch, we believe that a price-based approach is an appropriate and effective method to determine QM status. However, additional safeguards are necessary to ensure that the final rule effectively protects consumers and promotes access to responsible mortgage credit. In finalizing its rule, CFPB should ensure borrower protections for four key issues: fair lending, pricing caps, short-reset adjustable...
Introduction and Executive Summary Thank you for the opportunity to comment on the Federal Housing Finance Agency’s (FHFA’s) re-proposed rule on capital requirements for Fannie Mae and Freddie Mac (the governmentsponsored enterprises, or GSEs). In our view, the proposed rule erroneously treats the GSEs as banks and therefore requires banklike capital. This leads to gratuitously high capital levels that run directly contrary to the GSEs’ charter mission to promote access to mortgage credit to underserved borrowers, to serve a countercyclical role in the mortgage market, and to FHFA’s duty to...
Download the full letter from Wells Fargo's Michael DeVito, EVP of Head of Home Lending, to the U.S. Department of Housing and Urban Development regarding the Fair Housing Act Disparate Impact Rule.
On May 20, 2020, the Office of the Comptroller of the Currency (OCC) acted alone in issuing a structurally flawed final rule on the Community Reinvestment Act (CRA) that weakens the CRA and will harm low- and moderate-income (LMI) communities and communities of color. Rather than postpone rulemaking to focus on the devastating economic crisis caused by the COVID-19 health pandemic, the OCC issued the rule a mere six weeks after the closing of the comment period on its proposed rule despite broad requests for delay from community groups, civil rights and consumer organizations, and industry...
From the full comment letter : The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) strongly oppose the OCC and FDIC’s proposed Community Reinvestment Act (CRA) regulations.... The most troubling outcome of theproposed rule is that it would unwittingly sanction redlining. The proposal relies on an overly simplistic evaluation measurethat focuses on the total dollar value of CRA qualifying activity.We strongly oppose this approach, which we believe would fail to hold banks accountable for meeting the convenience and needs of all of their communities, as...