Research & Policy

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...

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...

CRL's comment argues against the proposed rule to limit the Bureau’s supervisory jurisdiction over non-depository institutions by interpreting the phrase “risk to consumers” in the Consumer Financial Protection Act to mean “a high likelihood of significant harm.” In the comment, CRL argues that the Bureau’s proposed interpretation conflicts with the plain meaning of the statute’s words, the statutory context provided...

In 2025, the Department of Education and Congress reshaped the student loan system through new laws, administrative actions, and proposed rules that could bring further changes. Together, these actions mean higher costs, fewer protections, and more uncertainty for millions of borrowers. Here is what is happening and how it could affect borrowers. Download the full factsheet. CRL Advocacy Priorities Protect...

Our new report shows that people who take out these loans experience steep costs as well as increasing financial stress due to increased use over time.

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...

The Center for Responsible Lending writes this comment to emphasize how the proposed rule’s vague and ambiguous standards would undermine program integrity, create a dangerous precedent for future administrations, and harm borrowers and the communities they serve.

CRL responded to the New York Department of Financial Services Request for Information Regarding Buy Now Pay Later, which requested comments from industry and interested parties on the “Buy-Now-Pay-Later Act" (L.2025, c. 58, Part Y, New York Banking Law Article 14-B). This law represents an essential step towards better protecting New York consumers from financial harm. Specifically, the Act provides...

Payday loan apps issue small, short-term loans that are typically repaid on the consumer’s next payday either directly from a bank account or as a payroll deduction. 1 Lenders market these loans as a means for workers to make ends meet between paychecks. In reality, workers who are already living paycheck-to-paycheck may find themselves pulled into a cycle of reborrowing...

In this comment, CRL applauds the Department of Housing and Urban Development for taking a critical first step in better understanding buy-now, pay-later financing effects by soliciting information from the general public and all concerned stakeholders. For the reasons discussed in this response, CRL believes that this important step should be followed, however, by focused research into the relationship between...

Improving consumer protection in this area has been one of the most pressing topics at statehouses across the country during the 2025 legislative session.

Watch the full testimony from Jaylon Herbin, Director of Federal Campaigns as he argues for strengthening the Public Service Loan Forgiveness (PSLF) program.

45 local and national advocates from across the country, including 20 from Maryland, urge Maryland’s Governor to veto HB1294, a bill that gives app-based payday lenders a special exemption from state laws that prohibit lending that is discriminatory, is deceptive, or carries extremely high interest rates.

The U.S. Department of Education’s commitment to reforming Title IV programs presents a historic opportunity to reshape the federal student aid system into one that is more equitable, efficient, and effective. CRL stands ready to support this process and urges the Department to center the needs of students—especially those that are first generational and underrepresented—in all forthcoming regulatory proposals.

The 349 undersigned consumer, civil rights, labor, legal services and community organizations and academics write to urge you to demand action to restore a strong and independent Consumer Financial Protection Bureau (CFPB). We further urge you to oppose changes to the CFPB’s funding, structure or other changes that would weaken its ability to stand up for consumers, competition and a...

In a letter to President Trump, a group of consumer, economic justice and civil rights organizations urge him to veto S.J. Res 18, which would overturn a Consumer Financial Protection Bureau rule that limits steep overdraft fees charged by large banks and credit unions.

Nearly 300 consumer, civil rights, labor, legal services and community organizations and academics wrote to oppose S.J. Res. 18 which would overturn the Consumer Financial Protection Bureau’s overdraft fee rule. This rule would reduce most overdraft fees from $35 to $5, stop manipulative practices by big banks, improve transparency, and put $5 billion back into the pockets of everyday people...

The undersigned 291 health care, consumer, civil rights, labor, legal services, and community organizations and academics write to urge you to oppose S.J. Res. 36 (Rounds) and H.J. Res. 74 (Norman), resolutions under the Congressional Review Act to rescind the Consumer Financial Protection Bureau’s (CFPB) final rule to remove medical debt from credit reports. We also oppose any attempt to...