Research & Policy

The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, NAACP, National Coalition for Asian Pacific American Community Development, National Fair Housing Alliance, and National Urban League file this comment in response to Fannie Mae's and Freddie Mac's (the Enterprises) proposed Underserved Markets Plans. Thank you for the opportunity to provide input on the Enterprises’ plans. The...

On Thursday, June 28th, Center for Responsible Lending (CRL) President Mike Calhoun testified before the Senate Committee on Banking, Housing, and Urban Affairs for a hearing entitled "Principles of Housing Finance Reform." In his written testimony, he stated that the "goal must be to ensure that the full universe of credit worthy borrowers – regardless of where they live, including...

The Center for Responsible Lending (CRL) sent a letter to House Financial Services Committee Chairman Jeb Hensarling (R-Texas) and Ranking Member Maxine Waters (D-Calif.) rebutting the committee’s majority staff report criticizing the Consumer Financial Protection Bureau’s (CFPB) role in investigating Wells Fargo’s fraudulent account scheme.

The Center for Responsible Lending (CRL) filed this comment in response to FHFA's proposed evaluation guidance for the Duty to Serve Rule. The evaluation guidance is the method for FHFA to assess Fannie Mae and Freddie Mac's (the Enterprises) Duty to Serve Underserved Markets Plans. The strength and clarity of the evaluation guidance will greatly inform the Enterprises' plans. A...

Last week, calls were made to eliminate the GSE affordable housing goals as a means to move forward legislation to reform the secondary housing finance market. This misguided attempt is not new, and it would harm creditworthy borrowers who cannot access the mortgage credit they deserve, deny them their chance at the American Dream of homeownership, and weaken our nation’s...

The Center for Responsible Lending (CRL) opposition letter details the many dangerous aspects of the bill.

Students at Maine’s for-profit colleges carry higher levels of debt, borrow in higher percentages, and have worse repayment rates on that debt compared to their peers at public and private non-profit institutions. Because African Americans, females, and low-income students are disproportionately enrolled in Maine’s for-profit colleges, these poor outcomes fall more heavily on these vulnerable subgroups. This report uses the...

Despite significant concerns raised by a number of interested parties—including hundreds of advocacy groups, state regulators, and a bipartisan group of Members of Congress—the OCC is moving forward with its fintech charter proposal. This comment letter asserts that the OCC does not have the legal authority to charter non-depositories, that a national bank charter for non-depository fintech institutions will facilitate...

This proposal was created by the undersigned consumer and civil rights groups in response to the United States Senate Committee on Banking, Housing, and Urban Affairs’ (Banking Committee) request for proposals to foster economic growth. The proposals revolve around 1) promoting responsible, sustainable homeownership and other responsible lending products for borrowers from low-and moderate income (LMI) households, communities of color...

On Tuesday, March 28, Center for Responsible Lending (CRL) President Mike Calhoun testified before the House Financial Services Committee's Financial Institutions and Consumer Credit Subcommittee for a hearing entitled "The State of Bank Lending in America." He discussed recent trends in lending and how the Dodd-Frank Wall Street Reform and Consumer Protection Act has made the financial industry more accountable...

Students at Connecticut’s for-profit colleges graduate at lower rates than their peers at public and private non-profit institutions. Those who do graduate carry higher levels of debt and higher default rates on that debt. Because African Americans and Hispanics are disproportionately enrolled in Connecticut’s for-profit colleges, these poor outcomes fall more heavily on people of color. This report uses the...

The OIRA Insight, Reform, and Accountability Act is portrayed as a mere codification of previous Executive Orders, but in fact it further undermines the rulemaking process. It would codify the numerous burdensome requirements contained in the orders– many of which are biased against protecting the public, vague, and in some cases mutually inconsistent — and would have the disastrous effect...

H.R. 1004 will significantly undermine federal agencies’ ability to engage and inform the public in a meaningful and transparent way regarding its work on important science-based rulemakings that will greatly benefit the public. As a result, the bill will lead to decreased public awareness and participation in the rulemaking process in direct contradiction of the Administrative Procedure Act and agencies’...

H.R. 998 would establish a new bureaucracy empowered to dismantle long-established science-based public health and safety standards and would make it significantly more difficult for Congress and federal agencies to implement essential future protections. Along with previous bills that have passed the House and the President’s Executive Orders instituting a regulatory freeze and requiring the removal of two rules for...

With little difference across party lines, Coloradoans expressed their strong support for a proposal requiring debt buyers, companies that buy old debts and attempt to collect on them, provide appropriate documentation for the debts they collect and sue on. Survey respondents were asked this question: Would you support or oppose a law requiring debt buyers to provide documentation to the...

Petitioners argue that the Budget Rules are arbitrary and capricious and unsupported by either the language of the statute or the record. This is not the case. The record abundantly supports each feature of the Budget Rules. In fact, the Budget Rules are a textbook balancing act by the Federal Communications Commission of the competing goals of the statute: to...

Students at Colorado’s for-profit colleges have less favorable outcomes in comparison to their peers at public and private non-profit institutions according to several key indicators, and the impact is greater on students of color. This report uses the data released from the US Department of Education (College Scorecard, September 2015) and compares public, private, and for-profit institutions (also referred to...

The Center for Responsible Lending (CRL), The Leadership Conference on Civil and Human Rights, and the NAACP have sent a letter to Comptroller of the Currency Thomas J. Curry urging him not to offer national charters to financial technology firms, which could severely undermine state oversight and state laws that protect consumers and small business owners from abusive financial products...

Over 250 consumer, civil rights, and community groups wrote this letter to the Office of the Comptroller of the Currency to express strong opposition to the proposed new federal nonbank lending charters that would enable lenders to avoid state interest rate caps, other state protections, and state oversight. State laws often operate as the primary line of defense for consumers...

Payday and car title loans are small-dollar, high-cost products that thrive on keeping consumers in a cycle of debt. With lenders doing essentially no underwriting, consumers find it easy to obtain these loans, often marketed as a solution to financial emergency. However, the unaffordability of the loan and the lenders extreme leverage over the borrowers – either through direct access...

Six years after the Great Recession, American households continue to struggle with consumer debt. According to data reported by the Urban Institute, approximately 77 million Americans – 35 percent of adults with credit files – have debt in collections reported on their credit files. These Americans carry about $1,349 in debt. About 31 percent of Colorado residents have debt in...

The 49 consumer, civil rights, small business, and other community organizations signed on to this letter to express strong opposition to new federal nonbank lending charters that would enable chartered entities to avoid state interest rate caps, other state consumer protection laws, and state oversight, putting consumers and small businesses at risk. The Office of the Comptroller of the Currency...

Lenders can and do make non-covered loans without regard to the borrower’s ability to repay as scheduled, and doing so can be highly profitable. In particular, high-cost loans provide a significant disincentive against lending based on ability to repay, even absent a coercive repayment mechanism or security. When rates are high, lenders can profit despite significant defaults and can even...

The Federal Deposit Insurance Corporation's (FDIC) proposed guidance provides a framework that will require banks to place more stringent requirements on the institutions that they conduct business with. However, as written, the proposed guidance will still enable consumer harm and allow FDIC-supervised institutions to engage in risky relationships with third parties via rent-a-bank lending. We are deeply concerned about the...

The Federal Housing Finance Agency (FHFA) should consider the impact credit risk transfer structures might have on borrowers. In bringing in private capital, FHFA should be careful to ensure that FHFA does not exchange access to credit or borrower protections for the capital the private market offers. We are concerned that the credit risk transfer programs have the potential to...