Predatory lenders are making loans of 100% APR or more in states with limits of 36% or less by laundering loans through an out-of-state bank that is not subject to state interest rate limits. This is a rent-a-bank scheme. Will these schemes make payday and high-cost lending legal everywhere? How can we protect our state interest rate limits? Why is this so important right now? CRL Resources April 23 Webinar - Time Running Out: Congress Should Repeal Rule Protecting Predatory Lenders Harming Small Businesses, Veterans, Consumers Correcting the Record: The OCC’s “Fake Lender” Rule Expands...
Payday, car-title, and similar high-cost loans, typically with interest rates of 100% APR and higher, trap people in crippling long-term debt. CRL advocates for regulators to require lenders to verify borrowers can afford to repay a loan before that loan is issued. CRL also advocates for interest rate caps of no higher than 36% APR and for enforcement of current usury laws.
Filter Results
The Center for Responsible Lending and several consumer, faith, community, and civil rights groups wrote to strongly oppose an Office of the Comptroller of the Currency (OCC)’s proposed rule that could unreasonably limit banks’ ability to decide not to serve particular entities, including payday and other predatory lenders. Download the comment letter.
On December 22, 2020, the Center for Responsible Lending (CRL) in partnership with several organizations submitted two letters to the OCC in regard to Oportun's application for a bank charter. CRL takes concern with Oportun's poor underwriting standards that harm the consumers they purport to serve; their intimidating debt collection practices; their new partnership with DolEx Check Cashing stores; and their discussion of the Community Reinvestment Act (CRA). CRL also highlights the need for Oportun to price its loans responsibly at a rate well below a fee-inclusive 36% for larger loans. The...
On December 22, 2020, the Center for Responsible Lending (CRL) in partnership with several organizations submitted two letters to the OCC in regard to Oportun's application for a bank charter. CRL takes concern with Oportun's poor underwriting standards that harm the consumers they purport to serve; their intimidating debt collection practices; their new partnership with DolEx Check Cashing stores; and their discussion of the Community Reinvestment Act (CRA). CRL also highlights the need for Oportun to price its loans responsibly at a rate well below a fee-inclusive 36% for larger loans. The...
Civil rights and consumer groups -- Center for Responsible Lending, National Consumer Law Center, East Bay Community Law Center, National Association for Latino Community Asset Builders, and National Coalition for Asian Pacific Americans Community Development – filed an amicus brief in support of the attorneys general of California, Illinois, and New York in their case against a rule from the Office of the Comptroller of the Currency (OCC) that encourages predatory lending through “rent-a-bank” schemes. The OCC rule facilitates non-bank lenders’ efforts to form superficial partnerships with...
The Center for Responsible Lending and the undersigned consumer, civil rights, community and faithbased organizations oppose the Bureau’s plans to engage in payday loan disclosure testing. We do so in the broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from the harms associated with payday lenders’ practice of making payday loans without reasonable ability-to-repay determinations. New disclosures would only provide a false veneer of...
A legacy of racial discrimination in housing, lending, banking, policing, employment, and otherwise, has produced dramatically inequitable outcomes that persist today. Communities of color, often largely segregated due to the history of redlining and other racially exclusionary housing policy, experience higher rates of poverty, lower wages, and higher cost burdens to pay for basic living expenses. Payday loans cause particular harm to these communities. Payday lenders target borrowers of color, in part by concentrating their locations in communities of color. Indeed, the communities most...
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...
In 2008, Ohio voters affirmed capping the cost of payday loans in the state at 28% interest; however, payday and car-title lenders engaged in schemes to evade the voter-mandated cap, trapping consumers in a cycle of debt with APRs of over 500%. In 2018, Ohio lawmakers approved some restrictions on these lending schemes, but even with these 2018 changes, payday lenders in Ohio are still charging over 100% APR and are not subject to requirements that ensure the loans can be repaid. Ohioans want real reform that has been proven to stop the debt trap—a rate cap of 36% or lower that includes fees...