New CRL research confirms that over the past decade, a Florida law that was enacted to protect Florida consumers from the predatory harms of payday lending has done the exact opposite. Instead, since 2005 payday loan borrowers in the Sunshine State have spent over $2.5 billion in payday loan fees. Further, Florida's senior citizens and consumers of color are the...
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View a letter from North Carolina organizations to Director Richard Cordray of the Consumer Financial Protection Bureau calling for a strong payday rule. North Carolina has a unique story to tell about payday lending. North Carolina was the first state to: Roll back a once legal payday industry Litigate the rent-a-bank model Force a bank to drop its bank payday...
Improving Language Access for Mortgage Applicants in the Uniform Residential Loan Application (URLA)
This joint letter expresses concern that an important opportunity to help improve language access for people who are not fluent in English is being lost. Allowing mortgage applicants to choose in which language they are most comfortable in communicating addresses a major problem of lenders and servicers working with limited English proficiency populations and collecting this information through the URLA...
CRL applauds FHFA for its recognition of the importance of the Duty to Serve mandate in the Housing and Economic Recovery Act of 2008 (HERA) and for putting forth a strong proposed rule. We strongly support much of what FHFA is proposing. The comments in this letter address numerous questions on which FHFA requests input, including general process, evaluation, and...
In a new report, the Center for Responsible Lending – along with Americans for Financial Reform – examines the impact of advocacy efforts of policy and regulation. The report take stock of both gains (actions that support or defend consumer protections) and losses (actions that jeopardize or reduce consumer protections) – specifically in the following areas: Federal legislation State legislation...
Cars are the most common nonfinancial asset held by American families, and for some families, their most significant asset. Cars have become a necessity for U.S households, with more than 85% of the U.S. workforce using an automobile to commute to work. Car ownership is no longer a luxury but is a prerequisite to economic opportunity. The need for a...
The consumer groups signing this letter oppose the Taking Account of Institutions with Low Operation Risk Act of 2015 (H.R. 2896) and amendments that will put consumers at risk from dangerous products or practices and undermine the established notice and comment process in place for financial regulations. If adopted, the TAILOR Act could allow financial institutions to justify and exploit...
A letter from seventeen consumer and civil rights advocacy groups to investor and auto dealer, Warren Buffett, urging him to help end discriminatory auto lending practices in this country. In 2014, Mr. Buffett's Berkshire Hathaway purchased the largest privately-held auto dealership group in the nation, the Van Tuyl Group. This letter calls attention to the widely documented problem of "racially...
This written testimony shares our work and insight into the subject of Raised Bill 5071, a bill that has the potential to cause significant harm to Connecticut residents seeking distance education opportunities. Two of key the consequences of the Uniform State Authorization Reciprocity Agreement (SARA) are: Elimination of local, state-centered control over distance education in the state Holding distance education...
The Holder Rule is one of the most important actions the Commission has ever taken in preventing and remedying unfair and deceptive practices in the marketplace. When a seller of a good or service originates or helps arrange credit, the Rule allows consumers to raise the seller’s misconduct as a basis for bringing claims or defenses against the entity holding...
Unfair debt collection practices, particularly those of debt buyers, undermine individuals' financial security, especially among low-income households and households of color. When people are pursued or sued for debt they do not owe, these unfair collection attempts not only threaten the unnecessary extraction of money from individuals, but also hinder opportunities to build assets for the future. Towards this end...
Public Opinion Strategies conducted a survey of 400 likely Republican caucus-goers in Iowa. The survey was conducted December 14-16, 2015 and has a margin of error of +4.9% in 95 out of 100 cases. Three hundred (300) interviews were conducted with land-line respondents and 100 interviews were conducted with cell phone respondents. Key findings included: Republican caucus-goers in Iowa are...
This letter is in response to the Department of Education's request for comments on the proposed Enterprise Complaint System ("ECS"). As advocates for students, consumers, veterans, faculty and staff, civil rights and college access, the signees believe the systematic tracking and reporting of student and borrower complaints is essential to providing quality customer service, ensuring college and loan servicer and...
This letter urges Chairman Kevin Brady and Ranking Member Sander Levin to reject H.R. 4294, the "SAVERS Act," and support the Department of Labor's (DoL) effort to strengthen retirement income security for working families and retirees. Far from being a pro-retirement security alternative to DoL rulemaking, the legislation would weaken the already inadequate protections afforded by current outdated regulations.
This letter to Chairman Pete Sessions and Ranking Member Louise Slaughter urges a strong opposition to H.R. 766, the Financial Institution Customer Protection Act of 2015, introduced by Representative Luetkemeyer. The bill will hamper critical Department of Justice and banking regulator efforts to detect fraud and money laundering, putting consumers and financial institutions at risk of serious financial loss. It...
The organizations represented on this sign-on letter asked President Obama to oppose any FY 2017 appropriations bills which include inappropriate ideological policy riders. Appropriations bills have been used before to undermine essential safeguards through "policy riders" – provisions that address extraneous policy issues, and are slipped into appropriations bills to win approval as part of must-pass funding legislation. Last year...
As strong supporters of the Department of Labor's (DoL) effort to strengthen retirement income security for working families and retirees, the undersigned on this letter urge the rejection of H.R. 4293, the "Affordable Retirement Advice Protection Act." Far from being a pro-retirement security alternative to DoL rulemaking, the legislation would weaken the already inadequate protections afforded by current outdated regulations...
Public Opinion Strategies conducted a survey of 500 likely voters in Michigan. The survey was conducted December 17-20, 2015 and has a margin of error of +4.3.8% in 95 out of 100 cases. Three hundred (300) interviews were conducted with landline respondents and 200 interviews were conducted with cell phone respondents. Key findings included: There is clear opposition to payday...
The Center for Responsible Lending1 submits this comment to provide additional context about the consumer installment loan market, in particular to highlight issues unaddressed by the proposed settlement with One Main and Springleaf. In this letter, the undersigned organizations bring to your attention three areas of concern that the settlement did not address, but which have a significant impact on...
The Center for Responsible Lending submits this comment to provide additional context about the consumer installment loan market, in particular to highlight issues unaddressed by the proposed settlement with One Main and Springleaf. In this letter, the undersigned organizations bring to your attention three areas of concern that the settlement did not address, but which have a significant impact on...
The 40 undersigned organizations oppose inclusion in any criminal justice reform package of "mens rea" (state of mind) provisions that would make it harder for prosecutors to criminally prosecute companies and corporate executives that engage in criminal wrongdoing. Specifically, there are various mens rea proposals, including mens rea legislation proposed in the Senate, that are premised on the belief that...
On behalf of our millions of members and supporters nationwide, these 45 groups urge the opposition of the so-called "Sunshine for Regulatory Decrees and Settlements Act of 2015" (H.R. 712), which would undermine citizen enforcement of our laws and impede the resolution of consumer protection, anti-discrimination, environmental protection, and other important cases before our federal courts. H.R. 712 targets consent...
More than 250 civil rights, consumer, labor, faith, veterans, seniors, and community organizations, strongly oppose H.R. 4018, the "Consumer Protection and Choice Act." This harmful bill would limit the Consumer Financial Protection Bureau's (CFPB) ability to protect all consumers against high-cost payday, car title, and installment loans. In addition to delaying the Bureau's rule-making for two years or longer, H.R...
Predatory consumer lending is still flourishing in California. Payday lending continues to be pervasive, capturing borrowers who were sold a short‐term loan in a long‐term cycle of debt. But high‐cost debt trap lending has expanded rapidly in the past few years to much larger loans, including some which are secured by and put a borrower’s car at risk. At the...
In Debt Collection Agencies and the Supply of Consumer Credit, Viktar Fedaseyeu examines state-level data to assess the effect of state laws limiting third-party debt collectors on the availability of revolving lines of credit (i.e., credit cards). The debt-buying industry claims that this paper demonstrates that consumers are harmed by these laws and thus regulations should be rolled back, or...