Research & Policy

The 90D+ delinquency (DQ) rate on loans insured by the Federal Housing Administration (FHA), which captures loans that are 90 or more days delinquent but not in foreclosure or bankruptcy, has increased sharply. At 3.57% in September 2025, it has since risen to 5.23% in January 2026, an increase of 1.66 percentage points (pp) in just 4 months. Market commentators...

Payday loan apps, often marketed as a low-cost or even “free” way to access wages early, are anything but. This one-pager explains how common features, such as expedite fees, so-called “tips,” and repeated small-dollar transactions, drive up the true cost of borrowing, resulting in triple-digit annual percentage rates for many users. This resource shows how the business model depends on...

The Military Lending Act (MLA) provides protections for active-duty service members and their families, including a 36% interest rate cap. This one-pager examines how payday loan apps, often marketed as Earned Wage Advance, attempt to evade these protections by claiming they are not loans. It also highlights a growing body of court decisions rejecting those claims and recognizing these products...

Payday loan apps offer small, short-term loans that are typically repaid on the consumers’ next payday. These products are sometimes called Earned Wage Advance, Early Wage Access, or EWA but few merit this name. Research by CRL and others has demonstrated using these apps leave many consumers worse off - paying high fees for small loans, increasing their risk of...

App-based Payday Lenders violate the Military Lending Act (“MLA”) by saddling military servicemembers with triple-digit debt. Multiple courts have rejected the lenders’ efforts to avoid compliance with the MLA. CRL is proud to stand with the servicemembers who wear the uniform as they fight unlawful high-cost debt-trap lenders that target their ranks. CRL filed a “friend of the court” brief...

CRL responded to the Federal Reserve Board regarding the Enova/Grasshopper merger, requesting the application for a bank holding company to be denied, or in the alternative, additional time of up to 60 days to comment, and to hold public hearings. This request is based on Enova’s record of high-cost lending of products that have interest rates over 100% and a...

CRL responded to the OCC regarding the Enova/Grasshopper merger, requesting additional time of up to 60 days to comment, and to hold public hearings. This request is based on Enova’s record of high-cost lending of products that have interest rates over 100% and a history of federal and state enforcement actions against them.

A coalition of more than 170 consumer, faith, civil rights, labor, human rights, and community advocacy groups sent a letter to Senators Elizabeth Warren and Tim Scott to enthusiastically support the Predatory Lending Elimination Act (S3793). This bill, sponsored in the Senate by Senator Jack Reed, is the solution to the worst practices by predatory lenders in the consumer loan...

CRL highlights the harms consumers face in the District of Columbia, which are similar to those associated with storefront payday loans. CRL offers its recommendations to the District of Columbia to consider as it moves forward with investigating and addressing payday loan apps. We recommend developing guidance to affirm the status of payday loan apps as credit under existing law...

Read our new analysis of borrowers caught in an unaffordable cycle of refinancing, including instances of refinancing two to three months after taking out an OppFi loan.

A recent study (commissioned by EarnIn) analyzing data from EarnIn’s Cash Out product has been promoted as evidence that the payday lending app marketed as earned wage access (“EWA”) improves workers’ financial stability by increasing income. A closer reading of the study, however, reveals the opposite: the reported income increase is likely driven by workers supplying more labor, while the...

Minnesotans had been charged a 220% APR on the typical storefront payday loan, but this predatory form of credit ended in 2024 when a strong interest rate cap went into effect.

Nadine Chabrier, CRL Senior Policy Counsel, teamed up with Molly Gallagher, Statewide Poverty Action Network Policy Lead, to talk to Washington state representatives about the importance of examining BNPL policy during the affordability crisis. Watch the full video to see Molly Gallagher's presentation and more.

The Department of Veterans Affairs (VA) holds 25% of the risk of loss associated with borrower default on VA-guaranteed mortgages. Therefore, VA has an economic interest in directing mortgage servicers to engage in risk management techniques that will reduce the number of defaults on VA-guaranteed loans that transition to disposition (i.e., foreclosure, short sale, or deed-in-lieu of foreclosure) and cause...

The purpose of this letter is to complement the National Fair Housing Alliance’s comment letter that CRL is a signatory on by focusing on the procedural deficiencies of the cost analysis section of the Notice of Proposed Rulemaking. Specifically, the comment letter highlights that none of the requisite requirements under the Regulatory Flexibility Act, Executive Order 12866, or § 1022(b)(2)...

The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, the League of United Latin American Citizens (LULAC), Legal Defense Fund, and National CAPACD - National Coalition for Asian Pacific American Community Development submitted a comment letter yesterday to the Consumer Financial Protection Bureau that opposes the CFPB’s Notice of Proposed Rulemaking (NPRM) that would delay and...

Original research about Colorado borrowers shows expensive credit is already burying people in debt, debunking argument for legalizing even costlier credit.

Nearly 200 labor, consumer, civil rights, and community organizations joined together to express opposition to any bill, similar to last year’s H.R. 7428 (Steil), that exempts earned wage payday loans from the Truth in Lending Act (TILA). Doing so would endorse a form of loan that makes workers pay to be paid and would facilitate new evasions by payday lenders...

CRL signed onto an amicus brief along with 39 other organizations to support a credible, politically independent and bipartisan FTC commission. The brief urges the Court to reaffirm Humphrey’s Executor 295 U.S. 602 (1935) and the for-cause requirement for terminations for the FTC and certain other governmental entities. The brief provides a number of specific examples of the importance of...

A panel of the U.S. Circuit Court of Appeals for the Tenth Circuit today held that Colorado can protect its residents from out-of-state loans from state-chartered banks that carry interest rates above what is permitted under Colorado law. Predatory rent-a-bank lenders charging rates up to 199% APR or higher have taken advantage of federal laws that allow banks to charge...

The Center for Responsible Lending, along with the Consumer Federation of America and National Consumer Law Center, filed an amici curiae on November 7, 2025. The amici are in support of plaintiff Eva Migligore’s request for en banc review at the US Court of Appeals for the Third Circuit to vacate the district court’s ruling to dismiss the case. The...

The Center for Responsible Lending agrees with the Federal Housing Finance Agency on the importance of acting intentionally and swiftly to positively address this nation’s housing challenges but believe that the proposed rule will not have the desired effect. Specifically: by reducing the low-income purchase goal by 4 percentage points (25% to 21%) for the next three years, nearly cutting...

Payday loan app companies try to evade state credit laws by promoting a legal fiction: they claim that these loans are not loans. As state regulators and attorneys general investigate and challenge industry violations of credit law, these lenders have lobbied state legislatures for exemptions from those laws. This state law chart serves as a shorthand guide to state regulation...

Payday loan apps draw borrowers into a pattern of repeated borrowing and a succession of fees that pull from already-stretched paychecks, creating demand for the next loan.

CRL signed onto an amicus brief supporting NTEU’s request for en banc review at the US Court of Appeals for the DC Circuit. NTEU requests the full court to review a decision that vacates a preliminary injunction in the lower case, which would allow the administration to reduce CFPB’s funding and fire its staff. This is the second amicus brief...