Mortgage Lending

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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Comment to the Federal Housing Finance Agency on Enterprise Housing Goals Advance Notice of Proposed Rulemaking

Comment to the Federal Housing Finance Agency on Enterprise Housing Goals Advance Notice of Proposed Rulemaking

The Center for Responsible Lending (CRL)1 appreciates the opportunity to comment on the Affordable Housing Goals Advance Notice of Proposed Rulemaking. In exchange for government support, Fannie Mae and Freddie Mac (GSEs) have an explicit public interest mission. This mission is foundational and part of their charters – the GSEs’ very reason for existing.2 The mission includes promoting access to...
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Comment Letter
Mortgage Lending

Comment to the Federal Housing Finance Agency on Prior Approval for Enterprise Products

Comment to the Federal Housing Finance Agency on Prior Approval for Enterprise Products

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...
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Comment Letter
Mortgage Lending

Comment on Request for Information on the Equal Credit Opportunity Act and Regulation B

Comment on Request for Information on the Equal Credit Opportunity Act and Regulation B

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.
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Comment Letter
Consumer Finance Mortgage Lending

Consumer, Civil Rights, and Housing Organizations Welcome the CDFI Fund's Focus on Community Development

Consumer, Civil Rights, and Housing Organizations Welcome the CDFI Fund's Focus on Community Development

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...
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Comment Letter
Mortgage Lending Payday and Other Small Dollar Loans

Comment: Urging the CDFI Fund to Establish Lending Standards for Certification or Renewal

Comment: Urging the CDFI Fund to Establish Lending Standards for Certification or Renewal

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...
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Comment Letter
Mortgage Lending Payday and Other Small Dollar Loans

Comment to the Federal Housing Finance Agency on 2021 Enterprise Housing Goals Proposed Rule

Comment to the Federal Housing Finance Agency on 2021 Enterprise Housing Goals Proposed Rule

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...
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Comment Letter
Mortgage Lending

Comment: Final Qualified Mortgage (QM) Rule Must Effectively Protect Consumers and Promote Access to Responsible Mortgage Credit

Comment: Final Qualified Mortgage (QM) Rule Must Effectively Protect Consumers and Promote Access to Responsible Mortgage Credit

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...
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Comment Letter
Mortgage Lending

Comment to the Federal Housing Finance Agency on Enterprise Regulatory Capital Framework

Comment to the Federal Housing Finance Agency on Enterprise Regulatory Capital Framework

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...
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Comment Letter
Mortgage Lending
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