Payday and Other Small Dollar Loans

The Office of the Comptroller of the Currency’s (OCC) “fake lender” rule is an existential threat to state interest rate limits that protect consumers from predatory lending. Since the American Revolution, states have limited interest rates to stop predatory lending. Forty-five states and the District of Columbia (DC) have interest rate caps on at least some installment loans, depending on...

The coalition of signatories to the letter consists of 325 groups, including civil rights, community, consumer, faith, housing, labor, legal services, senior rights, small business, student lending, and veterans organizations. The letter states that “[t]he rule replaces the longstanding ‘true lender’ anti-evasion doctrine with a ‘fake lender’ rule that allows lenders charging rates of 179% or higher to evade state...

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...

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...

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...

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...

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...

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...

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...