Research & Policy

A car purchase can expand economic mobility; but tricks and traps in auto financing can lead to harm and abuse. Among those tricks and traps is dealer interest rate markup. Car dealers can add extra interest to a car loan, and keep some or all of the difference. This practice has a long history of unfair and discriminatory impact. CRL...

Financial institutions drain billions of dollars annually from their customers through abusive overdraft fee practices. Frequently marketed as a “customer service,” overdraft fees are charged when a customer’s account lacks sufficient funds to cover a transaction and the institution pays the transaction anyway. The institution then repays itself the value of the overdraft transactions and all accompanying fees from the...

Explore each of the factsheets below for statistics related to that issue area and suggested reforms that could help to bring financial fairness to all. Auto Lending Debt Collection Mortgages Overdraft Fees Payday Lending Student Debt

Although debt collection plays an important role in how credit markets function, it can also expose American households to unnecessary abuses, harassment, and other illegal conduct. Unscrupulous debt collectors sometimes use incorrect data and illegal collection tactics to file lawsuits or pressure consumers into making payments on debt they may not owe. Even worse, millions of consumers become aware of...

Although marketed as quick cash for financial emergencies, payday and car-title loans typically become long-term debt that drains hundreds of dollars—if not thousands—from consumers. These small dollar loans carry average annual percentage rates of 391% that make it very difficult to escape a cycle of debt that can last months or years. Either through direct access to borrower bank accounts...

The organizations listed below submitted this comment letter to the Consumer Financial Protection Bureau (CFPB) on its new leadership’s proposed delay of a 2017 rule the agency had issued to stop payday and car title loans from trapping consumers in debt. The letter rebuts the CFPB’s rationale for proposing a 15-month delay of the payday rule, which the agency is...

Debt collection efforts around the United States rely heavily on litigation to collect past due debt. The ease of obtaining default judgments and garnishment orders has led debt buyers to use the courts as a critical tool for extracting payments from consumers, despite the lack of documentation showing that the consumer actually owes the amount claimed. Debt buyers are skilled...

SB 613 increases the rates for existing consumer loans in Indiana, adds additional high-cost loan products to the marketplace, and significantly increases the rates that are considered to be criminal loan sharking. For each of these changes, lenders are provided extraordinary leverage over the borrower, are able to structure the loans in a way that incentivizes repeat re-borrowing, and are...

In early February 2019, the current Consumer Financial Protection Bureau (CFPB) Director Kathy Kraninger released a proposal to gut the CFPB’s 2017 rule aimed at stopping payday and car title loans from trapping people in debt. Director Kraninger’s plan would repeal the heart of the 2017 payday rule, which generally requires that lenders determine a borrower’s ability to repay a...

This written testimony focuses on three key areas of concern in support of HB 2588 to protect Oregonians from abusive practices by student education loan servicers: Oregon’s student loan debt crisis deepens the racial wealth gap and harms older Oregonians Abuses by student loan servicers prolong and deepen the student loan debt crisis, further increasing the racial wealth gap and...

The Center for Responsible Lending (CRL) appreciates the opportunity to provide ideas on how to address racial disparities in student debt and the broader challenges faced by students of color in college and career training. We appreciate your commitment to addressing racial disparities in student debt and the broader challenges faced by students of color in college and career training...

The Center for Responsible Lending1 (CRL) appreciates the opportunity to provide comments on principles for the reauthorization of the Higher Education Act (HEA). We commend your dedication to reauthorizing the Higher Education Act with the intention of achieving an affordable, accountable, accessible and equitable and safer higher education system. We hope that you will continue to push for a Higher...

The following provides an overview of Consumer Financial Protection Bureau (CFPB) Director Kathy Kraninger’s proposal to repeal the CFPB’s 2017 rule aimed at stopping the debt trap of payday and car title loans. This document includes the Center for Responsible Lending’s (CRL’s) initial analysis of the purported rationale for the repeal. As we further consider the proposal, our reactions may...

This written testimony focuses on three key areas of concern: 1) abuses by student loan servicers prolong and deepen the problem of student loan debt; 2) For-profit schools disproportionately drive student loan debt nationally and in Colorado; and 3) the federal rollback of existing protections bolsters the need for state action. Download the full testimony. (PDF)

For-profit schools target students of color, low-income students, women, and veterans for enrollment, while failing to provide a quality education enabling students to obtain gainful employment. As is described below, New York for-profit students are more likely to have higher debt loads, lower graduation rates, and higher default rates than other students in the state. Consequently, an inordinate number of...

The Center for Responsible Lending (CRL) and the National Consumer Law Center (on behalf of its low income clients) (NCLC), joined by Americans for Financial Reform Education Fund, the Leadership Conference for Civil and Human Rights, and NAACP, submit these comments in response to the FDIC’s request for information (RFI) on small-dollar lending. We appreciate the FDIC’s ongoing work to...

By the Stop the Debt Trap Alliance of Oregon, in partnership with the Center for Responsible Lending (CRL) In 2006, when Oregonians noticed the devastating impact payday and car-title lending was having on their communities, a coalition pushed for a change in the state laws, bringing new consumer protections to hundreds of thousands of people in the state. This example...

One of the most prevalent problems with debt collection is harassing communications from debt collectors that violate consumers’ privacy and can cause serious harm to individuals and their families. In the Consumer Bureau’s survey on debt collection experiences, 42% of consumers who had been contacted by a collector in the past year reported that they had asked the collector to...

Existing racial wealth gap increases burden of student loan debt on Black families and communities: This means families of color are more likely to need to borrow for higher education, will have less income with which to pay it, and have less of a cushion to withstand future financial shocks, thus contributing to a higher likelihood of delinquency and default...

The Center for Responsible Lending (CRL) appreciates the opportunity to provide comments on our priorities for the reauthorization of the Higher Education Act (HEA). CRL applauds your initial efforts to tackle these policy reforms in H.R. 6543, The Aim Higher Act. We appreciate your dedication to create a bill that gets our country closer to providing a debt-free higher education...

Self-Help and the Center for Responsible Lending strongly oppose the Department of Homeland Security’s proposed rule to drastically expand the criteria that will be considered to determine whether an immigrant is likely to become a public charge. Being deemed a public charge is of tremendous consequence for individuals and families, as it permits the government to deny someone admission to...

Download the full text of the comment. In determining the capital standards for the GSEs, it is first critical to remember the primary drivers of the 2008 financial crisis and how those conditions have changed, affecting both the likelihood and severity of a future crisis. Next, the assumptions and mechanics of setting the capital regime must be closely examined in...

Today, the Center for Responsible Lending, Americans for Financial Reform, and other leading national labor, civil rights, consumer advocacy, fair housing, and legal services organizations responded in a joint comment to the Office of the Comptroller of the Currency’s (OCC) Advance Notice of Proposed Rulemaking (ANPR) on how the agency should update Community Reinvestment Act (CRA) procedures. The groups pressed...

These comments are submitted on behalf of the National Fair Housing Alliance (NFHA) and the Center for Responsible Lending (CRL) to express our organization’s strong support for effective enforcement of the Community Reinvestment Act, and our concern about the approach proposed by the OCC in the above-referenced Federal Register notice, dated September 5, 2018, entitled “Reforming the Community Reinvestment Act...

A 30-minute documentary produced by the Center for Responsible Lending, in cooperation with South Dakotans for Responsible Lending Before November 2016, payday and car title lenders in South Dakota charged annual interest rates up to 574%, trapping people in debt and often ruining their financial lives. The state legislature wouldn't pass reform, so South Dakotans put a 36% interest rate...