Payday and Other Small Dollar Loans

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.

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Polling Memo: Voters Support Strong Consumer Financial Protections and Tough Regulation of Wall Street

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...

Comment: Current CDFI Designation is Not Sufficient to Ensure that Loans Will Be Affordable and Responsible.

From the comment to the CDFI Fund on the Small Dollar Loan Program: The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), NAACP, Americans for Financial Reform Education Fund, Consumer Federation of America, and Public Citizen appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan Program (SDLP)...

OCC Proposed Rule Encourages Predatory Lending and Threatens to Eviscerate North Carolina’s Lending Laws

In a September 3 letter to Acting Comptroller of the Currency, Brian Brooks, the Coalition for Responsible Lending wrote: We oppose the OCC’s proposed rule to permit lenders to use the rent-a-bank model to avoid North Carolina’s rigorously enforced interest rate cap. The OCC’s proposed rule will let predatory lenders off the hook for charging interest and fees in excess...

Comment: OCC Rule Would Allow Payday Lenders to Use Rent-a-Bank Schemes to Evade State Laws

From the comment to the Office of the Comptroller of the Currency, Notice of Proposed Rulemaking, "National Banks and Federal Savings Associations as Lenders": We, the consumer and civil rights groups named above, write to strongly oppose the Office of the Comptroller of the Currency’s (OCC) proposed rule preempting the authority of states and courts to look beyond contrivances to...

OCC Proposed Rule Would Invite an Onslaught of Predatory Installment Lending into California

In a September 3 letter to Acting Comptroller of the Currency, Brian Brooks, the Californians for Economic Justice Coalition wrote: California has strong interest rate caps on installment loans intended to protect our residents from predatory loans. Understanding that products like payday loans, car-title loans, and high-cost installment loans at sky high interest rates are merely debt traps for borrowers...

OCC Proposed Rule Would Trample State Interest Rate Limits and Unleash Predatory Lending in all 50 States

More than 100 community, consumer, civil rights, and faith organizations wrote to vigorously oppose the OCC’s proposed rule to gut the longstanding "true lender" anti-evasion doctrine. The proposed rule would trample state interest rate limits and unleash predatory lending in all 50 states, further exacerbating the economic impacts already experienced by COVID-19.

Overview: CFPB’s Repeal of its 2017 Ability-to-Repay Standard for Payday & Car Title Loans

The Consumer Financial Protection Bureau (CFPB), under Director Kathy Kraninger, gutted a 2017 CFPB rule aimed at stopping the debt trap caused by payday and car title loans. This action will have a harmful impact on American consumers and their families, including a disproportionate number of people of color. Download the one-pager to learn more.

The OCC and FDIC Plan to Trample State Laws by Gutting the Longstanding “True Lender” Doctrine

For years, predatory lenders have sought ways to avoid state interest rate limits. One scheme has been the “rent-a-bank” scheme. Under this scheme, a non-bank lender finds a bank willing to be the nominal originator of the non-bank lender’s high-cost loan, because banks are generally exempted from complying with state interest rate laws. State regulators, state attorneys general, and consumers...

Amicus Brief Regarding Lacewell v OCC 2nd Circuit

From the amicus brief: This case concerns the authority of the Office of the Comptroller of the Currency (OCC) to extend the privileges of national banks to entities that do not accept deposits and are not banks in any traditional or legal sense. The foremost reason why non-banks will seek out a “special purpose national bank” is to take advantage...

Industrial Loan Company Charters Pose Risks to Consumers and the Economy: A Moratorium Is Needed

Industrial loan companies (ILCs) or industrial banks (IBs) (together, “ ILCs”) typically enjoy the privileges of traditional banks but pose two significant risk factors unique to ILCs: They are not subject to the Federal Reserve’s supervision, which occurs at the consolidated level (i.e., the ILC’s parent company, the ILC, and their affiliates); and They permit the intermingling of commercial and...
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