Research & Policy

The undersigned consumer and civil rights organizations appreciate the opportunity to submit comments on the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed rule on debt collection. As organizations dedicated to eliminating abusive financial practices – particularly focused on communities of color and low- to moderate-income consumers – we are deeply concerned about the proposed rule’s content and impact. Without...

The 232 undersigned consumer, civil and human rights, labor, community and legal services organizations from all 50 states and the District of Columbia submit the following comments on the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed debt collection rules. The rule as proposed does far more to protect abusive debt collectors than consumers. The proposal opens consumers up to...

Download this factsheet for more information on the top three principles against rent-a-bank arrangements: Long Precedent Against Rent-A-Bank Schemes Has Served Banks and Consumers Well. More Recent Rent-a-Bank Arrangements (with FDIC-supervised banks) Include Grossly Irresponsible Loans. Change in Course Would Invite Risk, Backlash, and Erosion of Confidence in Banking System.

The Center for Responsible Lending (CRL), The Leadership Conference on Civil and Human Rights, NAACP, National Urban League, and UnidosUS appreciate the opportunity to respond to the Consumer Financial Protection Bureau’s (CFPB or Bureau) Advance Notice of Proposed Rulemaking (ANPR) on the Qualified Mortgage (QM) definition under the Truth in Lending Act (TILA) and Ability to Repay / Qualified Mortgage...

Earlier this year, the Consumer Financial Protection Bureau proposed new rules for debt collectors. The proposal authorizes, for the first time, a specific number of communication attempts to collect past-due debts. The rules also authorizes new means of communicating with people to collect debts, such as email and direct messaging, and expands the ability to collect time-barred debt. Download the...

The growth of outstanding student loan debt over the last decade has been staggering. Today, more than 44 million people carry over $1.5 trillion of outstanding student loan debt, an amount that exceeds all other types of non-mortgage loan debt. Two out of three graduates in the class of 2017 borrowed federal student loan debt to finance their education.2 This...

From the letter to the director of the National Economic Council, Lawrence Kudlow: As you consider proposals to restructure our nation’s housing finance system as required by the March 2019 Presidential Memorandum,1 the undersigned civil rights organizations write to express our collective view that any effort to comprehensively reform Government Sponsored Entities (GSEs)—Fannie Mae and Freddie Mac—must recognize the importance...

Currently in the United States, approximately 43 million people owe over $1.4 trillion on their federal student loans. Americans owe more in student loan debt than for auto loans, credit cards, or any other non-mortgage debt.2 Student loan servicers play a critical role in these borrowers’ financial lives, from receiving and applying payments to interacting with struggling borrowers to facilitate...

While pursuing higher education is still a pathway to higher incomes over a person’s lifetime, student loan debt threatens to undermine this promise in North Carolina and nationwide. Outstanding student loan amounts have risen at an alarming rate over the past decade, and North Carolina has not been immune from this trend. Today, students and their families face a difficult...

Consumer watchdog groups urged the U.S. Consumer Financial Protection Bureau (CFPB) to take action immediately to implement the payment provisions in its payday lending rule, whose compliance date is August 19, 2019. These provisions restrict payday and vehicle-title lenders from attempting to withdraw money from borrowers’ bank accounts after two attempts have failed, a practice that significantly harms struggling consumers...

Higher education has long been considered a pathway for advancement in our country. However, the playing field has not been level for low- and moderate-income families and people of color in their pursuit of a postsecondary education. Sadly, the resulting disparities in educational outcomes contribute to the persistent and growing racial wealth and income gaps. Nationwide, trends in the higher...

"Regarding State Authorization of Distance Education providers enrolling students across multiple states, we voice here our support for those provisions of the NPRM that preserve the State Authorization rules finalized in 2016 and currently in effect. The 2016 rules provide core protections to consumers and protect states’ rights to enforce their own laws in two key areas. First, the rules...

In the Dodd-Frank Act, Congress required lenders to make a reasonable and good faith determination that the borrower has the ability to repay a mortgage loan (ATR) before the loan is made. It also created a category of loans, called Qualified Mortgages, or QM, that are presumed to comply with the ATR requirement given product and borrower credit characteristics that...

The 24 undersigned community, consumer, civil rights, and faith groups write regarding the Consumer Financial Protection Bureau (CFPB or the Bureau)’s review of the 2009 Regulation E overdraft opt-in rule under the Regulatory Flexibility Act (RFA). Weakening the opt-in rule in any way is clearly unsupportable; rather, protections against unfair and abusive overdraft fees should be substantially strengthened. Today’s overdraft...

The considerations prescribed by the RFA strongly support strengthening protections against overdraft fees on debit card and ATM transactions. More broadly, comprehensive reform of unfair and abusive overdraft practices is badly needed. The RFA sets forth five factors to consider in an RFA review. Consideration of these factors in the opt-in rule context shows clearly that any effort to weaken...

A coalition of national consumer and civil rights groups wrote letters to three top banking regulators – the FDIC, OCC and Federal Reserve – on the importance of preventing the reemergence of debt-trap bank payday loans. View the letter to the FDIC, letter to the OCC, and letter to the Fed. These letters were signed by Americans for Financial Reform...

Student loan borrowers of color disproportionately bear the brunt of America’s student debt crisis, and sadly, the extraordinary levels of delinquency and default across these communities is preventable. The most vulnerable student loan borrowers have a right under federal law to make affordable student loan payments—a powerful protection that should make student loan defaults extremely rare. However, mounting evidence shows...

The Center for Responsible Lending (CRL), as part of a coalition of civil rights, consumer, and labor groups, submitted an official comment letter to the Consumer Financial Protection Bureau (CFPB), excoriating CFPB Director Kathy Kraninger’s plan to gut a 2017 CFPB rule that was issued to stop payday loan debt traps. The coalition’s comment letter, submitted on the last day...

Homeownership is the primary way that most middle-class families build wealth and achieve economic stability. Wide access to credit is critical for building family wealth, closing the racial wealth gap, and for the housing market overall, which in turn, contributes significantly to our overall economy. Today, the opportunity to purchase, maintain and refinance a home has not reached significant portions...

On April 30, 2019, the House Financial Services Committee’s Subcommittee on Consumer Protection and Financial Institutions convened a hearing on “ Ending Debt Traps in the Payday and Small Dollar Credit Industry.” Download the full written and oral testimony of CRL's Diane Standaert below: Download the full testimony. (PDF) Download the oral testimony. (PDF) Watch Diane Standaert's opening statement and...

Payday and car-title loans typically carry annual percentage rates (APR) of at least 300%. These high-cost loans are marketed as quick solutions to a financial emergency. Research demonstrates, however, that they frequently lead to debt that is nearly impossible to escape. In addition, these loans are related to a cascade of other financial consequences, such as increased overdraft fees, delinquency...

Until 2010, for-profit institutions constituted the fastest growing sector in higher education. Coinciding with this growth, online college courses and programs expanded rapidly, driven initially by the adoption of online technologies by huge for-profit institutions like the University of Phoenix, Grand Canyon University, and Walden University. The business model for the online component of these schools was characterized by institutional...

Our Housing Finance System and the GSEs provide essential services to families and lenders across the country. Rural borrowers, small lenders and lower wealth borrowers particularly benefit from these services because the GSEs provide access to a national market, making home loans more affordable overall. The GSEs, though, had critical flaws leading up to the crisis. Since then, fundamental reforms...

Higher education can be the gateway to a better life. Yet the rising costs of a college education and poor oversight of student loans have left some graduates and former students deep in debt—especially when enrolled in for-profit colleges. The Center for Responsible Lending (CRL) found that students of color enroll more frequently in for-profit colleges than other students, graduate...

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...