In response to the Request for Comments issued by the Consumer Financial Protection Bureau, the Center for Responsible Lending, the Consumer Federation of America, and the National Consumer Law Center (on behalf of its low-income clients) offer joint recommendations for further guidance and monitoring of the growing Buy-Now-Pay-Later market overall, which are specific to the "pay-in-four" model. Our comment covers...
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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Payday lenders often describe the cost of their loans in terms of fees or simple interest rates. Responsible lenders readily disclose the APR on their loans, aligned with the Truth in Lending Act (TILA). They are not afraid to let their customers compare the costs of their loans to other loans in the market. Tellingly, payday lenders often object to...
New polling data shows that Rhode Island voters across all political parties are broadly supportive of consumer protections to lower the maximum annual interest rate for payday loans in the state.
With a new chairman taking the helm of the Federal Deposit Insurance Corporation (FDIC), the Center for Responsible Lending joined with more than a dozen other organizations in calling for the FDIC to "stop permitting its supervised institutions to front for predatory lenders evading state interest rate limits."
The Center for Responsible Lending (CRL), the National Association of Latino Community Asset Builders (NALCAB), and the National Coalition for Asian Pacific American Community Development (National CAPCACD), along with eleven undersigned public interest groups submitted comments to the Consumer Financial Protection Bureau in regards to its proposed rule to implement Section 1071 of the Dodd-Frank Wall Street Reform and Protection...
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.
From the beginning of the comment letter: The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), Americans for Financial Reform Education Fund, and Consumer Federation of America appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan (SDL) Program Application. The comments focus on aspects of the application...
On November 2, 2021, Marisabel Torres, director of California Policy, CRL testified before the House Task Force on Financial Technology. Her written testimony as well as her oral remarks are available for download. Watch the live hearing:
The Center for Responsible Lending (CRL), the Consumer Federation of America (CFA), the National Consumer Law Center (NCLC) (on behalf of its low-income clients), and the National Fair Housing Alliance (NFHA) submitted a comment on the Proposed Interagency Guidance on Third-Party Relationships with an emphasis the following points: A handful of FDIC-supervised banks are engaged in high-cost rent-a-bank schemes, which...
The CFPB should rescind the Bureau’s November 2020 EWA Advisory Opinion or to revise its unsound reasoning to prevent evasions of credit laws. The CFPB should also revisit the December 2020 Compliance Assistance Sandbox Approval Order regarding PayActiv for the same reason, and to order PayActiv to cease misusing the order. We also urge the Bureau to eliminate or significantly...