Research & Policy

Email House Financial Services Committee members to reject any EWA bill that fails to protect workers and families from harmful fees, debt traps, and predatory practices.

As living costs continue to rise and the federal student loan system is being fundamentally restructured, millions of borrowers are caught between increasing household expenses and a repayment system that is becoming harder to navigate. Understanding the financial condition of the borrower population before these changes take full effect matters because policy changes interact with the financial circumstances of the...

On June 22, CRL joined over 60 organizations in calling on the Federal Reserve System to hold public hearings on the application of Enova and Opportunity Financial to acquire BNC Bank and to become bank holding companies.

Read the new paper that provides firsthand accounts and analysis of the challenges of purchasing a car in today’s economy, particularly for borrowers with lower incomes or subprime credit scores.

On May 20, 2026 Mitria Spotser submitted written testimony to the United States House Committee on Financial Services. Watch the full video of the committee:

The 103 undersigned consumer, civil rights, and community organizations wrote to Chairman Scott, Ranking Member Warren, Chairman Hill and Ranking Member Waters urging them to defend and strengthen interest rate limits and transparency to address the affordability crisis by: Insisting that the Trump Administration deny applications from Enova and OppFi, lenders that charge annual interest rates of 100% APR and...

This litigation tracker compiles key cases addressing payday loan app products. It highlights how courts and enforcement authorities are analyzing core issues such as whether advances constitute “credit,” how fees and tips are treated under applicable law, and whether these products trigger protections like the Military Lending Act’s 36% rate cap and other disclosure and anti-evasion requirements. So far, every...

The Center for Responsible Lending (CRL) and the National Consumer Law Center (NCLC) continued with their advocacy on behalf of payday loan app users in the courts, filing an amicus (friend of the court) brief in the Ninth Circuit Court of Appeals to support Staff Sergeant John Revell's individual claims and on behalf of putative classes against Grant Money, LLC...

This proposed rule is the OCC’s initial attempt at implementing a regulatory framework under the GENIUS Act for payment of stablecoin activities. CRL answered question 43 recommending that at account opening and on monthly statements there is a plain language disclosure informing consumers that these accounts are not insured by the FDIC. CRL also joined Americans for Financial Reform on...

Civil rights and consumer advocacy organizations urge the Federal Reserve Board to deny an application to become a bank holding company, submitted by Enova, raising particular concern about the effects of its predatory lending on communities of color. This nonbank lender has disproportionate number of complaints from majority-minority communities, charges triple-digit interest rates, has charge-off rates (a measure of defaults)...

CRL opposes the implementation of this proposed rule and any changes to HUD’s current eligibility status. The proposed rule will result in mixed-status families not been able to live as a family unit in subsidized housing. CRL put forth the following arguments in support of its position: The plain text of 42 U.S.C. §1436a(b)(2) and §1436a(c)(1)(A) demonstrates that Congress intended...

The NAACP encouraged Maryland Governor Wes Moore to sign into law legislation that would restore some protections for people using payday loan apps.

CRL submitted comments to Acting Director Vought arguing the draft Strategic Plan retreats from the Bureau's statutory obligations at a moment of acute consumer affordability pressure, raising 3 core concerns: Fair banking is defined too narrowly. Objective 1.1 centers almost entirely on ideological debanking under EO 14331, with no mention of ECOA, fair lending, or the racial wealth gap. Objective...

The Center for Responsible Lending (CRL) and the National Consumer Law Center (NCLC) continued with their advocacy on behalf of payday loan app users in the courts, filing an amicus (friend of the court) brief in the Ninth Circuit Court of Appeals to support Petty Officer Samuel Vickery and Sargeant Rae Fuller’s class action lawsuit against lender Empower Finance, Inc...

The 90D+ delinquency (DQ) rate on loans insured by the Federal Housing Administration (FHA), which captures loans that are 90 or more days delinquent but not in foreclosure or bankruptcy, has increased sharply. At 3.57% in September 2025, it has since risen to 5.23% in January 2026, an increase of 1.66 percentage points (pp) in just 4 months. Market commentators...

Payday loan apps, often marketed as a low-cost or even “free” way to access wages early, are anything but. This one-pager explains how common features, such as expedite fees, so-called “tips,” and repeated small-dollar transactions, drive up the true cost of borrowing, resulting in triple-digit annual percentage rates for many users. This resource shows how the business model depends on...

Payday loan apps offer small, short-term loans that are typically repaid on the consumers’ next payday. These products are sometimes called Earned Wage Advance, Early Wage Access, or EWA but few merit this name. Research by CRL and others has demonstrated using these apps leave many consumers worse off - paying high fees for small loans, increasing their risk of...

The Military Lending Act (MLA) provides protections for active-duty service members and their families, including a 36% interest rate cap. This one-pager examines how payday loan apps, often marketed as Earned Wage Advance, attempt to evade these protections by claiming they are not loans. It also highlights a growing body of court decisions rejecting those claims and recognizing these products...

App-based Payday Lenders violate the Military Lending Act (“MLA”) by saddling military servicemembers with triple-digit debt. Multiple courts have rejected the lenders’ efforts to avoid compliance with the MLA. CRL is proud to stand with the servicemembers who wear the uniform as they fight unlawful high-cost debt-trap lenders that target their ranks. CRL filed a “friend of the court” brief...

CRL responded to the Federal Reserve Board regarding the Enova/Grasshopper merger, requesting the application for a bank holding company to be denied, or in the alternative, additional time of up to 60 days to comment, and to hold public hearings. This request is based on Enova’s record of high-cost lending of products that have interest rates over 100% and a...

CRL responded to the OCC regarding the Enova/Grasshopper merger, requesting additional time of up to 60 days to comment, and to hold public hearings. This request is based on Enova’s record of high-cost lending of products that have interest rates over 100% and a history of federal and state enforcement actions against them.

A coalition of more than 170 consumer, faith, civil rights, labor, human rights, and community advocacy groups sent a letter to Senators Elizabeth Warren and Tim Scott to enthusiastically support the Predatory Lending Elimination Act (S3793). This bill, sponsored in the Senate by Senator Jack Reed, is the solution to the worst practices by predatory lenders in the consumer loan...

CRL highlights the harms consumers face in the District of Columbia, which are similar to those associated with storefront payday loans. CRL offers its recommendations to the District of Columbia to consider as it moves forward with investigating and addressing payday loan apps. We recommend developing guidance to affirm the status of payday loan apps as credit under existing law...

Read our new analysis of borrowers caught in an unaffordable cycle of refinancing, including instances of refinancing two to three months after taking out an OppFi loan.

A recent study (commissioned by EarnIn) analyzing data from EarnIn’s Cash Out product has been promoted as evidence that the payday lending app marketed as earned wage access (“EWA”) improves workers’ financial stability by increasing income. A closer reading of the study, however, reveals the opposite: the reported income increase is likely driven by workers supplying more labor, while the...