Research & Policy

The following organizations signed on to a letter to Michael Hsu, Acting Comptroller of the Office of the Comptroller of the Currency, urging him to act and ensure that OCC-supervised banks make necessary reforms to their inequitable overdraft programs. Accountable.US Americans for Financial Reform Education Fund California Reinvestment Coalition Center for Responsible Lending Consumer Action Consumer Federation of America Consumer...

A report released in January of 2023 attempts to provide cover for the predatory practices of payday lenders, who charge average 400% annual interest on loans that routinely create a long-term cycle of debt that sends borrowers into deep financial insecurity. The Consumer Financial Protection Bureau (CFPB) found that 75% of payday lender fees are collected from borrowers with 10...

In response to the questions posed in the VA’s October 17, 2022 Advance Notice of Proposed Rulemaking, the National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending urge VA to expand the opportunities available to help veteran borrowers avoid foreclosure. The mortgage relief options available for veteran borrowers should not be less favorable...

Previous research by the Center for Responsible Lending (CRL) has revealed the harms associated with high-cost installment loans, which are often marketed to subprime borrowers and have annual percentage rates of interest (APRs) in excess of 36%. This paper explores a different segment of the installment loan market: loans made by consumer finance companies with rates at or below 36%...

On December 14th, Mitria Spotser, a consultant for the Center for Responsible Lending (CRL) testified before the House Committee on Veterans Affairs hearing on a discussion draft bill, the VA Housing Loan Forever Act of 2022. Her written testimony is available for download and the recorded video is available below.

From the letter to the U.S. Department of Veterans Affairs (VA): The dramatic increase in interest rates since the turn of the year has significantly reduced the effectiveness of VA’s current loan modification program. As a result, an additional loss mitigation option is needed to help veterans who cannot afford to resume their originally scheduled mortgage payments and are in...

In this letter, several financial services industry and consumer groups expressed support for legislation, introduced in the U.S. Senate, to close the industrial loan company (ILC) charter loophole, the “Close the Shadow Banking Loophole Act."

New data from the bipartisan polling team Lake Research Partners and Chesapeake Beach Consultingi shows that voters across the political spectrum overwhelmingly support the ongoing mission of the Consumer Financial Protection Bureau (CFPB) to regulate the financial industry and protect consumers. The new findings are consistent with over 10 years of opinion research demonstrating strong public support for the agency’s...

The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund strongly support the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. In November 2020, CRL and Self-Help urged the Fund to adopt several critical consumer protections in the Fund’s certification application. We are...

A broad coalition of consumer groups filed comments supporting the CDFI Fund’s changes to the application for CDFI certification. In recent years, many harmful financial products have been pushed on underserved communities in the name of “access to credit” and “financial inclusion.” Most CDFIs stay away from these harmful products and are true to their mission but far too many...

As of the end of August 2022, 350,000 FHA borrowers were seriously delinquent. Some of these borrowers will regain their financial footing, cure their delinquency, and resume their monthly payments, while others will sell their homes. The remainder will need a reduction in their monthly payment to an affordable level to remain in their home. However, the combination of the...

The National Consumer Law Center (on behalf of its low-income clients), the Center for Responsible Lending, and the National Housing Law Project submitted this comment to the Consumer Financial Protection Bureau in response to a request for information regarding mortgage refinances and forbearances.

More than 44 million people in the United States—roughly one in six adults—collectively hold more than $1.6 trillion in federal student loan debt. Although many Americans are burdened by their student loan debt, borrowers who attended Historically Black Colleges and Universities (HBCUs) have been especially hard hit, due to the impacts of systemic racism on wealth accumulation for families and...

The Protecting Wages Act will keep more money in the pockets of working people struggling to pay rent and put food on the table, while still allowing the collection industry to collect debts. Protects Enough Wages for Basic Needs From Seizure: Protects $1,000 in disposable earnings per week from being seized for old debts, or 75% of disposable earnings, whichever...

The Public Service Loan Forgiveness (PSLF) Program is a federal program that forgives loan balances for those working for the government or in the nonprofit sector after 120 qualifying payments. Download the factsheet to take advantage of this temporary expanded benefit before October 31st.

Over the past decade, the high-cost small-dollar loan market, once dominated by short-term balloon payment payday loans, has seen the rise of high-cost installment loans with longer terms. Payday loans are typically repaid in a lump-sum, usually due in 14-day periods. Installment loans tend to be larger in size and repaid in several installments, typically over a period of several...

The market for personal loans is massive and growing, yet the fintechs and other non-bank lenders who make such loans are not subject to regular oversight by the Consumer Financial Protection Bureau (CFPB), which has “created an unlevel playing field and a large risk to consumers,” write the Consumer Bankers Association (CBA) and the Center for Responsible Lending (CRL). The...

The Center for Responsible Lending (CRL), American Business Immigrant Coalition (ABIC), and more than 20 consumer, civil rights and advocacy groups and lenders, recently submitted a letter urging the U.S. Treasury Department and U.S. Small Business Administration (SBA) to reverse the Good Faith Error Rule that has prevented more than 300,000 small business owners from obtaining forgiveness of Paycheck Protection...

Letter signed by 110 national, state, and local consumer, civil rights, legal services, community, public interest organizations, consumer attorneys, and others in comment on the FTC’s Notice of Proposed Rulemaking (NPRM) on the sale, financing, and leasing of motor vehicles by dealers.

Cars are essential for most households in the United States, but access to a safe, affordable vehicle is increasingly limited for many consumers by sharply rising prices, burdensome accompanying debt obligations, and problematic dealer practices. The cost of a vehicle represents such a significant proportion of many American households’ total annual income that over 88% of new car purchases and...

Morning Consult conducted a survey, commissioned by Center for Responsible Lending. The poll is presented as a short Powerpoint-style slide deck with key takeaways and charts. Key findings include: Millions struggled to meet their basic needs due to the burden of student debt Low-income borrowers in loan forgiveness programs were more likely to skip meals and face wage garnishment throughout...

Amid growing concern about corporate consolidation, the Center for Responsible Lending (CRL) and Americans for Financial Reform Education Fund are leading a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank. Their comment letter points to several reasons why regulators should...

On August 18, 2022, Nadine Chabrier, senior litigation and policy counsel for the Center for Responsible Lending, provided testimony at a public meeting of the Office of the Comptroller of the Currency (OCC) and the Federal Reserve System on the proposed merger of TD Bank and First Horizon Bank.

The National Coalition for Asian American Community Development (National CAPACD), the Center for Responsible Lending (CRL), and the National Association for Latino Community Asset Builders (NALCAB) are pleased to submit collective recommendations as the Building Back Better for Entrepreneurs of Color partnership to the interagency request for public input regarding the Community Reinvestment Act.

The Center for Responsible Lending and Center for Community Self-Help applaud the effort of the Agencies to update and modernize the CRA regulations given the massive changes that have taken place in the financial services industry in the more than 25 years since the regulations were last amended. Likewise, we support the overall thrust of the Agencies’ proposal, which provides...