Research & Policy

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...

Consumer, civil rights, faith, and community groups are urging the FDIC Chair in this letter to keep in place the agency’s guidance urging banks to not sell these toxic loan products, which are harmful to consumers, banks’ reputation, and its safety and soundness. The coalition’s letter also calls for the FDIC to ensure small dollar installment loans are capped at...

In recent years, payday lenders have drained over half a billion dollars in fees from Michigan consumers to out-of-state companies. By charging APRs over 340%, payday lenders cost Michigan consumers over $94 million in 2016 and over $513 million over the past five years. Over two-thirds of Michigan payday stores have headquarters out of state. Michigan payday lenders disproportionately locate...

In 2008, the majority of Ohio voters affirmed capping the cost of payday loans in the state to 28% interest, inclusive of all fees and other charges. Since that time, payday and car title lenders have evaded the voter-mandated cap, engaging in schemes to charge rates reaching over 300% annual percentage rate (APR), and even higher than 500% APR. In...

CRL director of federal advocacy, Scott Astrada, appeared before the U.S. Senate Committee on Health, Education, Labor & Pensions (Subcommittee on Primary Health and Retirement Security) on August 21, 2018 to deliver testimony on the “Financial Literacy: The Starting Point for a Secure Retirement."

Dear Coalition Supporters, This update covers important predatory lending developments over the past few months, including action at the NC General Assembly, challenge of the payday rule in Congress (spoiler, we won!), threats to our state usury cap, rollback of federal student loan protections, and recent CRL research. NC General Assembly: What Happened? House Bill 810, backed by the NC-based...

An application to file brief and brief of amici curiae, Center for Responsible Lending, National Association of Consumer Advocates, Public Citizen Inc, and Public Good Law Center in support of applelants, Eduardo de la Torre, et al.

A recent poll conducted by Lake Research Partners and Chesapeake Beach Consulting shows overwhelming concern among voters regarding the level of student debt. Across parties, a majority of voters agree that the amount of student loan debt represents a crisis, with 71% of Democrats, 67% independents, and 57% of Republicans in agreement. Almost three in five independents (58%) strongly agree...

According to new data released recently by the FDIC, the largest banks in America collected $11.45 billion in overdraft and non-sufficient funds (NSF) fees from American consumers in 2017, an increase of approximately $10 million over the 2016 total. Overdraft fees often impose a great burden on those already living paycheck to paycheck, struggling to make ends meet. Typically, a...

We urge NCUA to make no changes to the payday alternative loan (PAL) program that would increase the likelihood that credit union members end up in cycles of high-cost, short-term loans that resemble payday loan debt. Most critically, we strongly oppose permitting more than six application fees in twelve months as proposed for PAL II. We also oppose permitting 28%...

We thank NCUA for its efforts to protect credit union members from payday loans. In recent years, the number of federal credit unions (FCUs) we are aware of engaging in payday lending, either directly or indirectly through credit union service organizations (CUSOs), has decreased to a single FCU. And through both its regular rules and its PAL program, NCUA has...

The “Stop Overdraft Profiteering Act of 2018,” introduced by Senators Booker and Brown, would address extremely high-cost overdraft fees financial institutions charge on checking accounts. Banks’ overdraft practices exploit the financially vulnerable, leaving them worse off and driving many from the banking system altogether. The bill would establish reasonable safeguards for checking account holders; restore transparency to the checking account...

Lump sum single balloon payment payday loans with a two-week term have historically dominated the payday loan market. A shift in recent years, due to regulatory or industry changes, has been for payday lenders to make payday loans with longer terms due in multiple installment payments, each due on or around the borrower’s payday. Payday lenders often market these products...

Voters of all political parties overwhelmingly oppose the actions taken by Mick Mulvaney to undermine the mission of the Consumer Financial Protection Bureau (CFPB) and feel a strong connection between lax enforcement of the rules on Wall Street and their daily welfare, according to a new poll release by Americans for Financial Reform (AFR) and the Center for Responsible Lending...

In response to the Education Department’s stated interests to end an 18-year old departmental practice of sharing information with law enforcement officials, the Center for Responsible Lending recently wrote comments urging Secretary Betsy DeVos to continue the productive and long-standing exchanges. Citing recent collaborations that together returned or forgave more than $36 million to harmed consumers in just four states...

On May 31, 2018, the parties to this action filed a joint motion asking the Court to stay both this litigation and the principal compliance date of the Consumer Financial Protection Bureau (CFPB)’s regulation on payday, vehicle title, and certain high-cost installment loans, 12 C.F.R. part 1041 (“Payday Rule”), at issue in the case. In support of their request for...

Before the court in the above styled and numbered cause is the parties' Joint Motion for Stay of Litigation and Stay of Agency Action Pending Review filed May 31, 2018 (Clerk's Document No. 16). By the motion the parties move the court for the following: (1) a stay of this litigation pending agency rulemaking to reconsider Defendant Consumer Financial Protection...

The marketing of for-profit colleges is ubiquitous, yet student outcomes are consistently poor. These outcomes include high dropout rates, low and unstable earnings of graduates, and heavy debt burdens that students are unable to repay, often resulting in default and ruined credit. The reliance of for-profit colleges on federal student aid dollars compounds these harms and fuels these poor student...