Research & Policy

HUD/FHA is proposing to amend language on their certification forms where lenders certify that a loan is eligible for FHA financing (insurance). We believe the proposed language is a step in the right direction, but we offer additional suggestions. The components of our recommended framework to FHA include providing a certification that includes provisions for all of the following: The...

On July 13 CRL submitted this comment letter detailing its concerns with the state of student loan servicing.

Certification plays an important role in protecting the health of the Federal Housing Administration's (FHA) mutual mortgage insurance fund so that millions of Americans—many of whom are first-time buyers, come from low and moderate-income backgrounds, or purchase homes in communities of color—can continue to become successful homeowners. Certification also serves another equally important purpose by requiring lenders to certify that...

CRL joined a sign on letter with over 100 consumer, student, education, civil rights, labor, and veterans groups detailing their concerns about the lack of oversight of student loan servicing.

From the letter: We, the undersigned organizations, are based in states throughout the U.S. that ban payday lending and other types of high-cost, predatory small-dollar loans. We write to you from our perspectives as military associations, social service providers, faith leaders, affordable housing agencies, legal service providers, labor organizers, and civil rights advocates. Read the entire letter. (PDF)

Comment of the Center for Responsible Lending and the National Consumer Law Center (on behalf of its low income clients) on the Proposed Amendments to the Cash Management Rule, 34 C.F.R. Part 668. Also see broad coalition comments to the Department of Education

A letter to the president of the National Automobile Dealers Association, calling on him to release the data showing the amount customers who finance cars pay in dealer interest rate markup.

Today, the Center for Responsible Lending (CRL) filed a public comment on urgently needed rules proposed by the California Department of Business Oversight (DBO) that would require payday lenders to follow California law by prohibiting the use of electronic transfers and debit cards in payday transactions. The rules would also create a new real-time electronic database to enforce existing law...

In this final chapter of The State of Lending in America and its Impact on U.S. Households series, we demonstrate the cumulative high costs of lending abuses, discuss lessons learned from efforts to address predatory lending, and suggest steps for further action. This chapter comprises the following sections: Lending Abuses and Their Costs describes how various types of lending abuses...

State of Lending provides an across-the-board survey of financial products that Americans use to handle everyday transactions, buy homes and automobiles, and build savings and wealth. The report outlines predatory lending practices in various fields of consumer lending, and explains why protecting fair, affordable access to credit is vital for both consumers and the U.S. economy. The report also describes...

On May 12, 2015, the Senate Committee on Banking, Housing, and Urban Affairs' Chairman, Senator Richard Shelby (R-AL), introduced a discussion draft of "The Financial Regulatory Improvement Act of 2015" ("Chairman's Draft"). The proposal comes at a time when offering community banks relief from recently created laws and regulations for the mortgage market is dominating some discussions about Congressional efforts...

CRL, The Public Good Law Center, and the National Association of Consumer Advocates filed an amicus brief supporting an appeal by plaintiffs asserting that loans made by the payday lender CashCall were unconscionable and violated California's Unfair Competition Law. Courts and the common law have long recognized that excessive interest rates and prices are unconscionable and therefore "unfair" and "unlawful."...

The Center for Responsible Lending applauds the CFPB for its continued focus on student loan servicing. Good loan servicing benefits both the borrower and the lender by helping borrowers successfully pay down their loans. As the CFPB holds a field hearing on student loan servicing today in Milwaukee, we offer seven ideas for a fair student loan servicing system: Prevent...

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. Download a summary of the full report. 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...

Testimony by Paul Leonard from the May 6, 2015 Informational Hearing on the Consumer Financial Protection Bureau Rulemaking for Payday, Vehicle Title and Similar Loans before the California Senate Banking Committee. The CFPB aims to cover payday and similar loans under its rule regardless of the provider or channel offering the loans (storefront and online; bank/credit union, non-depository, tribal entity)...

A recent blog on the Washington Post site took Senator Elizabeth Warren to task for citing a statistic in a report from the Center for Responsible Lending (CRL). Our report quantified the amount that consumers pay in auto dealer markups. Auto dealers are paid large bonuses to raise the rate on auto loans above the rate that consumers qualify for...

When colleges and banks team up to market bank accounts to students, protecting students' loan funds may take last place in the deal. Instead of helping students find the best account for them, these deals may push students into accounts with high overdraft fees and other harmful features. CRL research shows that overdraft fees alone on these accounts may reach...

On April 23, 2015, the New York Senate Banks Committee held a public hearing on subprime auto lending. Lisa Stifler (policy counsel at CRL) submitted written testimony on the predatory and abusive practices that have thrived due to the lack of regulation and transparency in auto financing.

Recent enforcement actions against debt buyers by state and federal law enforcement agencies illustrate widespread problems in the debt buyer market that must be addressed. The Federal Trade Commission recommends in its 2013 and 2010 reports that states adopt reform efforts to address these market problems. Based on its review of enforcement actions, industry data, and the FTC's reports, CRL...

Fifteen student, consumer, civil rights, and labor groups co-signed a letter (4 pages) in support of the Consumer Financial Protection Bureau's proposed rule on prepaid cards. The groups suggest that the new rule would support similar actions by the Department of Education, aimed to protect students using prepaid cards. The groups state: College students are a key segment of the...

In this letter to Consumer Financial Protection Bureau Director Richard Cordray the Center for Responsible Lending and the National Consumer Law Center respond to the agency's Request for Information about the Student Safe Account Scorecard, which would guide colleges to select safe bank accounts if they enter into marketing partnerships with banks. In the letter, the two organizations support the...

Fifteen consumer, student, civil rights, and legal aid groups co-signed a letter to Consumer Financial Protection Bureau Director Richard Cordray in response to the agency's Request for Information about the Student Safe Account Scorecard. The organizations supported the Scorecard and stated: Colleges and universities must begin to put the best interest of students first when negotiation with banks and prepaid...

On April 15, 2015, Mitria Wilson testified before the U.S. House Committee on Financial Services: Subcommittee on Financial Institutions and Consumer Credit. The hearing at which Mitria testified was called "Examining Regulatory Burdens on Non-Depository Financial Institutions." In her testimony (19 pages), Mitria offered: An overview of the importance of financial regulations - and the role such regulations currently play...

Debt buyers purchase old debts from creditors for pennies on the dollar and then hire debt collectors or attorneys to force consumers to pay up, often by suing them in court. Recent enforcement actions by state and federal regulators show widespread abuse and improper lawsuits brought to try to collect the old debt. Abuses include things like robo-signing affidavits in...

In response to a request for comment, CRL offered feedback to the Consumer Financial Protection Bureau about the agency's proposed rule addressing prepaid cards. The CFPB's proposed rule would expand consumer protections on prepaid cards in significant respects. The CRL comment focuses on credit products associated with prepaid cards – with a particular focus on overdraft fees. The CRL comment...