The Consumer Financial Protection Bureau (CFPB) issued a Policy Statement on Abusive Acts and Practices and invited comments from the public. The Center for Responsible Lending applauds the CFPB for its efforts to further clarify abusive acts and practices. The Center further offers insights into how the statement may be strengthened to clarify the ways these acts take unreasonable advantage of a consumer’s inability to protect their interests in selecting or using a product.
Excessive overdraft fees charged by banks and credit unions can cause devastation for financially vulnerable families. Many lenders used predatory policies and practices designed to repeatedly extract excessive fees from customers who could least afford them. Overdraft fees are a leading cause of financial institutions closing a consumer’s account and reentry into the banking system often is exceedingly difficult, increasing the financial insecurity of many consumers. CRL advocates for legislators and regulators to rein in the size and frequency of these fees. We estimate that the savings from these fee eliminations will be between $3 billion to $4 billion for working families.
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In response to a Federal Trade Commission (FTC) notice that it intends to issue regulation, CRL joined a coalition of consumer groups in calling for FTC action to rein-in junk fees. Among other topics, this comment letter highlights a CRL report on installment loan companies that would tack on credit insurance and “automobile club memberships” – charges that meet multiple characteristics of junk fees, including that they’re often a surprise to the consumer and that their value to the consumer is limited or nonexistent. The letter was also signed by: Accountable.US AKPIRG American Economic...
The following organizations signed on to a letter to Michael Hsu, Acting Comptroller of the Office of the Comptroller of the Currency, urging him to act and ensure that OCC-supervised banks make necessary reforms to their inequitable overdraft programs. Accountable.US Americans for Financial Reform Education Fund California Reinvestment Coalition Center for Responsible Lending Consumer Action Consumer Federation of America Consumer Reports The Leadership Conference on Civil and Human Rights NAACP National Consumer Law Center (on behalf of its low-income clients) Revolving Door Project UnidosUS...
Amid growing concern about corporate consolidation, the Center for Responsible Lending (CRL) and Americans for Financial Reform Education Fund are leading a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank. Their comment letter points to several reasons why regulators should deny the application , including TD Bank’s exceptionally poor treatment of consumers and an exacerbation of the “too-big-to-fail” problem if the merger is approved. Co-signatories are Alaska PIRG, American...
On August 18, 2022, Nadine Chabrier, senior litigation and policy counsel for the Center for Responsible Lending, provided testimony at a public meeting of the Office of the Comptroller of the Currency (OCC) and the Federal Reserve System on the proposed merger of TD Bank and First Horizon Bank.
Letter to the CFPB from 79 consumer, housing, civil rights, legal services, faith, community, small business, and financial organizations groups regarding supervision and enforcement of fintech products and fee models that threaten to evade credit, consumer protection, and fair lending laws.
This statement was entered for the record for the July 21, 2021 hearing on “Banking the Unbanked: Exploring Private and Public Efforts to Expand Access to the Financial System” before the U.S. House Committee on Financial Services, Subcommittee on Consumer Protection and Financial Institutions. Download the testimony above or view a webcast of this hearing .
From the comment letter: NCUA’s proposal, which would permit federal credit unions (FCUs) to keep members’ negative account balances open for longer than the current limit of 45 days, offers no evidence that it will achieve its stated goal -- to provide relief to FCU members. At the same time, the proposal fails to consider the significant risks it poses members or include elements to mitigate those risks. Credit union overdraft practices, like those of banks, most heavily impact the financially vulnerable and leave them worse off. During the best of times, any NCUA action related to overdraft...
Ten years after passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, with the country again facing an economic crisis, new polling data from Lake Research Partners, commissioned by the Center for Responsible Lending and Americans for Financial Reform shows that voters across all political parties are broadly and intensely supportive of strong consumer financial protections and of tough regulation of the financial services industry. Download the: Polling memo Toplines Time series
The Center for Responsible Lending (CRL), Self-Help Federal Credit Union, Self-Help Credit Union, and the National Consumer Law Center (on behalf of its low income clients) (NCLC) write to share concerns with the Interim Final Rule on Overdraft Policy that was considered and tabled at NCUA’s May Board meeting. Unfortunately, the proposal fails to offer members relief from overdraft fees so desperately needed during the COVID-19 crisis, while subjecting members to additional risks from overdraft programs. In addition, as an interim final rule, the proposal would inappropriately bypass the...