Research & Policy

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 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...

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...

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...

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...

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...

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...

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...

In the last decade, student loan debt has exploded, directly impacting the lives of millions of Americans and leaving its mark on the entire economy. There are currently over 44 million Americans with student loan debt. With the costs of higher education continuing to rise at alarming rates and a college education becoming a requirement for more and more jobs...

This important hearing addresses how technological innovation has resulted in the development of new services and delivery platforms by both traditional financial institutions and non-bank fintech companies. The rapid expansion of market participants and their products has brought new opportunities, as well as significant consumer protection concerns, to the financial marketplace. In my written testimony I will discuss in detail...

The Center for Responsible Lending (CRL) files this comment in response to the above referenced U.S. Department of Education’s Notice of Proposed Rulemaking (NPRM) which rescinds the 2014 gainful employment (GE) regulations. CRL is deeply troubled by the Department’s decision to do away with these important accountability requirements that protect both the welfare of career training students and the taxpayer...

The Center for Responsible Lending (CRL) files this comment in response to the above referenced U.S. Department of Education’s Notice of Proposed Rulemaking (NPRM) which rescinds the 2014 gainful employment (GE) regulations. CRL is deeply troubled by the Department’s decision to do away with these important accountability requirements that protect both the welfare of career training students and the taxpayer...

The brief filed in Student Loan Servicing Alliance v. Taylor, et al. urges the court to reject the plaintiff loan servicer association’s “federal preemption” argument, which claims that existing federal law bars states and the District from engaging in any regulatory oversight of loan servicers. As the brief highlights, this preemption argument is legally unfounded and unwise. In fact, D.C.’s...

Both the GSEs and Ginnie Mae continue to provide critical mortgage capital to underserved communities. The GSEs purchased more than two million homes and refinance mortgage loans in 2015, including almost half a million loans to low- and moderate-income borrowers, nearly 400,000 loans to borrowers of color and over 300,000 loans to borrowers living in rural areas. At the same...

On this tenth anniversary of the financial crisis, there have been many retrospectives on the US government’s response to that catastrophe, with more to come. The commentary to date has largely focused on the extraordinary measures taken to prevent a much deeper collapse of the American and global economies. Measures were implemented to address the immediate crisis and reduce the...

The Center for Responsible Lending (CRL) files this comment in response to the U.S. Department of Education’s proposed rule that would amend the Borrower Defense to Repayment provision of the Higher Education Act (HEA) and rescind and rewrite previously promulgated regulations from 2016. CRL is extremely concerned about the Department’s decision to rewrite rules meant to protect students and taxpayers...

The Center for Responsible Lending (CRL) files this comment in response to the U.S. Department of Education’s proposed rule that would amend the Borrower Defense to Repayment provision of the Higher Education Act (HEA) and rescind and rewrite previously promulgated regulations from 2016. CRL is extremely concerned about the Department’s decision to rewrite rules meant to protect students and taxpayers...

Florida is fertile ground for studying for-profit education, given the industry’s outsized presence there and a weak state regulatory environment. In the early summer of 2017, The Center for Responsible Lending (CRL) conducted focus groups in Orlando, Florida with 75 individuals who had attended for-profit colleges within the last 10 years and borrowed to finance their education. The research sought...

"The undersigned consumer, community, and civil rights organizations write to urge the Consumer Financial Protection Bureau to reverse its recent decision to suspend the supervision of payday, car title, and other lenders for violations of the Military Lending Act (MLA). We also urge the Department of Defense to ensure that the Military Lending Act is vigorously implemented without exemptions or...