Banks Must Adhere to Long-Established Sound Banking Principles
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 encourage banks to meet consumers’ needs and to promote a more inclusive banking system. Indeed, we are very concerned about the persisting racial disparities the new FDIC unbanked/underbanked survey...