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November 2025 EarnIn Study Shows the Harms of Payday Loan Apps (“EWA”)

A recent study 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 payday lending app...

Statewide Poverty Action Network and CRL Testify at Washington Legislature Work Session on Buy Now, Pay Later (BNPL)

Nadine Chabrier, CRL Senior Policy Counsel, teamed up with Molly Gallagher, Statewide Poverty Action Network Policy Lead, to talk to Washington state representatives about the importance of examining BNPL policy during the affordability crisis. Watch the full video to see Molly Gallagher's presentation and more.

Comment on Equal Credit Opportunity Act - Regulation B

The purpose of this letter is to complement the National Fair Housing Alliance’s comment letter that CRL is a signatory on by focusing on the procedural deficiencies of the cost analysis section of the Notice of Proposed Rulemaking. Specifically, the comment letter highlights that none of the requisite requirements under the Regulatory Flexibility Act, Executive Order 12866, or § 1022(b)(2)...

CRL and National Civil Rights Groups Oppose CFPB Proposal to Weaken Small Business Lending Transparency Rule 

The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, the League of United Latin American Citizens (LULAC), Legal Defense Fund, and National CAPACD - National Coalition for Asian Pacific American Community Development submitted a comment letter yesterday to the Consumer Financial Protection Bureau that opposes the CFPB’s Notice of Proposed Rulemaking (NPRM) that would delay and...

Labor, Civil Rights, Consumer, Legal Services and Community Groups and Academics Oppose Any Bill that Exempts Earned Wage Payday Loans from the Truth in Lending Act (TILA)

Nearly 200 labor, consumer, civil rights, and community organizations joined together to express opposition to any bill, similar to last year’s H.R. 7428 (Steil), that exempts earned wage payday loans from the Truth in Lending Act (TILA). Doing so would endorse a form of loan that makes workers pay to be paid and would facilitate new evasions by payday lenders...

CRL Signs Amicus Brief Supporting a Politically Independent FTC

CRL signed onto an amicus brief along with 39 other organizations to support a credible, politically independent and bipartisan FTC commission. The brief urges the Court to reaffirm Humphrey’s Executor 295 U.S. 602 (1935) and the for-cause requirement for terminations for the FTC and certain other governmental entities. The brief provides a number of specific examples of the importance of...

CRL Files Amicus Brief Supporting Consumer Credit Rights in Solar Fraud Case

The Center for Responsible Lending, along with the Consumer Federation of America and National Consumer Law Center, filed an amici curiae on November 7, 2025. The amici are in support of plaintiff Eva Migligore’s request for en banc review at the US Court of Appeals for the Third Circuit to vacate the district court’s ruling to dismiss the case. The...

Comment on Federal Housing Finance Agency’s Notice of Proposed Rulemaking on the 2026-2028 Enterprise Housing Goals

The Center for Responsible Lending agrees with the Federal Housing Finance Agency on the importance of acting intentionally and swiftly to positively address this nation’s housing challenges but believe that the proposed rule will not have the desired effect. Specifically: by reducing the low-income purchase goal by 4 percentage points (25% to 21%) for the next three years, nearly cutting...

State-by-State Action on Payday Loan Apps

Payday loan app companies try to evade state credit laws by promoting a legal fiction: they claim that these loans are not loans. As state regulators and attorneys general investigate and challenge industry violations of credit law, these lenders have lobbied state legislatures for exemptions from those laws. This state law chart serves as a shorthand guide to state regulation...

Amicus Brief In Support of NTEU’s Request for En Banc Review at the US Court of Appeals for the DC Circuit

CRL signed onto an amicus brief supporting NTEU’s request for en banc review at the US Court of Appeals for the DC Circuit. NTEU requests the full court to review a decision that vacates a preliminary injunction in the lower case, which would allow the administration to reduce CFPB’s funding and fire its staff. This is the second amicus brief...

CRL Comment on Legal Standard Applicable to Supervisory Designation Proceedings

CRL's comment argues against the proposed rule to limit the Bureau’s supervisory jurisdiction over non-depository institutions by interpreting the phrase “risk to consumers” in the Consumer Financial Protection Act to mean “a high likelihood of significant harm.” In the comment, CRL argues that the Bureau’s proposed interpretation conflicts with the plain meaning of the statute’s words, the statutory context provided...

Student Loan Borrower Protections Under Threat Factsheet

In 2025, the Department of Education and Congress reshaped the student loan system through new laws, administrative actions, and proposed rules that could bring further changes. Together, these actions mean higher costs, fewer protections, and more uncertainty for millions of borrowers. Here is what is happening and how it could affect borrowers. Download the full factsheet. CRL Advocacy Priorities Protect...

Payday Loan Apps

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...

Comment on the Notice of Proposed Rulemaking Concerning the Public Service Loan Forgiveness (PSLF) Program

The Center for Responsible Lending writes this comment to emphasize how the proposed rule’s vague and ambiguous standards would undermine program integrity, create a dangerous precedent for future administrations, and harm borrowers and the communities they serve.

CRL Comments on Innovative NY Buy-Now, Pay-Later (BNPL) Law

CRL responded to the New York Department of Financial Services Request for Information Regarding Buy Now Pay Later, which requested comments from industry and interested parties on the “Buy-Now-Pay-Later Act" (L.2025, c. 58, Part Y, New York Banking Law Article 14-B). This law represents an essential step towards better protecting New York consumers from financial harm. Specifically, the Act provides...

Payday Loan Apps: States Should Regulate As Credit, Protect Consumers

Payday loan apps issue small, short-term loans that are typically repaid on the consumer’s next payday either directly from a bank account or as a payroll deduction. 1 Lenders market these loans as a means for workers to make ends meet between paychecks. In reality, workers who are already living paycheck-to-paycheck may find themselves pulled into a cycle of reborrowing...

Comment on Buy-Now, Pay-Later Unsecured Debt

In this comment, CRL applauds the Department of Housing and Urban Development for taking a critical first step in better understanding buy-now, pay-later financing effects by soliciting information from the general public and all concerned stakeholders. For the reasons discussed in this response, CRL believes that this important step should be followed, however, by focused research into the relationship between...

Local & National Advocates Urge Maryland Governor to Veto Bill Authorizing Predatory Lending Apps

45 local and national advocates from across the country, including 20 from Maryland, urge Maryland’s Governor to veto HB1294, a bill that gives app-based payday lenders a special exemption from state laws that prohibit lending that is discriminatory, is deceptive, or carries extremely high interest rates.
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