Research & Policy

This letter urges the opposition of HR 1261 or any similar bills that undermine the independence of the Consumer Financial Protection Bureau (CFPB) by subjecting it to the appropriations process. It is less than five years since the CFPB was established. Since then, it has fulfilled Congress's vision of a federal agency with "the authority and accountability to ensure that existing consumer protection laws and regulations are comprehensive, fair, and vigorously enforced." Through its rulemaking, supervision, enforcement, and consumer education and complaint system, the CFPB has made enormous...

In a Statement for the Record to the Hearing of the Senate Committee on Banking, Housing, and Urban Affairs: Assessing the Effects of Consumer Finance Regulations, CRL expresses its support for post-crisis lending rules that have made the financial system safer by eliminating abusive financial products, reining in reckless behavior, and encouraging more effective oversight.

Debt buyers, specialized debt-collection companies, purchase defaulted consumer debt from creditors such as credit card companies for pennies on the dollar. Debt buyers then attempt to collect the debt, often by suing borrowers in court. Unfortunately, because debts are typically sold to debt buyers without fully verifying the accuracy of the borrower's identity, amount of the debt, or status of repayment, the information used as a basis to collect from consumers may be faulty. As a consequence, borrowers can find themselves facing a default judgment from court on a debt that they do not in...

New CRL research confirms that over the past decade, a Florida law that was enacted to protect Florida consumers from the predatory harms of payday lending has done the exact opposite. Instead, since 2005 payday loan borrowers in the Sunshine State have spent over $2.5 billion in payday loan fees. Further, Florida's senior citizens and consumers of color are the most likely to become borrowers at one of the state's many storefront locations.

View a letter from North Carolina organizations to Director Richard Cordray of the Consumer Financial Protection Bureau calling for a strong payday rule. North Carolina has a unique story to tell about payday lending. North Carolina was the first state to: Roll back a once legal payday industry Litigate the rent-a-bank model Force a bank to drop its bank payday loan product

This joint letter expresses concern that an important opportunity to help improve language access for people who are not fluent in English is being lost. Allowing mortgage applicants to choose in which language they are most comfortable in communicating addresses a major problem of lenders and servicers working with limited English proficiency populations and collecting this information through the URLA is the most comprehensive way to do so, because every mortgage borrower fills one out.

CRL applauds FHFA for its recognition of the importance of the Duty to Serve mandate in the Housing and Economic Recovery Act of 2008 (HERA) and for putting forth a strong proposed rule. We strongly support much of what FHFA is proposing. The comments in this letter address numerous questions on which FHFA requests input, including general process, evaluation, and public review, as well as specific comments on the three market areas.

In a new report, the Center for Responsible Lending – along with Americans for Financial Reform – examines the impact of advocacy efforts of policy and regulation. The report take stock of both gains (actions that support or defend consumer protections) and losses (actions that jeopardize or reduce consumer protections) – specifically in the following areas: Federal legislation State legislation Federal regulatory actions Federal judicial actions State regulatory actions State judicial actions Industry practices In addition, the report takes stock of efforts that have yet to yield specific...

Cars are the most common nonfinancial asset held by American families, and for some families, their most significant asset. Cars have become a necessity for U.S households, with more than 85% of the U.S. workforce using an automobile to commute to work. Car ownership is no longer a luxury but is a prerequisite to economic opportunity. The need for a car is particularly true for many low- and moderate-income families (LMI) and communities of color, who live or work beyond the reach of public transit systems. Given the role that cars play in the everyday lives of American families, we applaud...

The consumer groups signing this letter oppose the Taking Account of Institutions with Low Operation Risk Act of 2015 (H.R. 2896) and amendments that will put consumers at risk from dangerous products or practices and undermine the established notice and comment process in place for financial regulations. If adopted, the TAILOR Act could allow financial institutions to justify and exploit potentially dangerous loopholes, create confusion in the marketplace and cause unnecessary delays in the adoption of important consumer protections. Prudential and consumer regulators already have broad...

A letter from seventeen consumer and civil rights advocacy groups to investor and auto dealer, Warren Buffett, urging him to help end discriminatory auto lending practices in this country. In 2014, Mr. Buffett's Berkshire Hathaway purchased the largest privately-held auto dealership group in the nation, the Van Tuyl Group. This letter calls attention to the widely documented problem of "racially motivated and discriminatory auto dealer markups."

This written testimony shares our work and insight into the subject of Raised Bill 5071, a bill that has the potential to cause significant harm to Connecticut residents seeking distance education opportunities. Two of key the consequences of the Uniform State Authorization Reciprocity Agreement (SARA) are: Elimination of local, state-centered control over distance education in the state Holding distance education providers to insufficient standards

The Holder Rule is one of the most important actions the Commission has ever taken in preventing and remedying unfair and deceptive practices in the marketplace. When a seller of a good or service originates or helps arrange credit, the Rule allows consumers to raise the seller’s misconduct as a basis for bringing claims or defenses against the entity holding the debt. Specifically, the Rule requires a notice in the credit documents that assignees in credit sales and direct lenders related to sellers are subject to claims and defenses that the consumer has against the seller of the goods or...

Unfair debt collection practices, particularly those of debt buyers, undermine individuals' financial security, especially among low-income households and households of color. When people are pursued or sued for debt they do not owe, these unfair collection attempts not only threaten the unnecessary extraction of money from individuals, but also hinder opportunities to build assets for the future. Towards this end, strong, effective rules to prevent unfair practices can help keep hard earned wages in consumers’ pockets and build pathways to financial security. In this comment regarding the...

This letter is in response to the Department of Education's request for comments on the proposed Enterprise Complaint System ("ECS"). As advocates for students, consumers, veterans, faculty and staff, civil rights and college access, the signees believe the systematic tracking and reporting of student and borrower complaints is essential to providing quality customer service, ensuring college and loan servicer and collector accountability, and preventing waste, fraud, and abuse of taxpayer dollars.

Public Opinion Strategies conducted a survey of 400 likely Republican caucus-goers in Iowa. The survey was conducted December 14-16, 2015 and has a margin of error of +4.9% in 95 out of 100 cases. Three hundred (300) interviews were conducted with land-line respondents and 100 interviews were conducted with cell phone respondents. Key findings included: Republican caucus-goers in Iowa are strongly opposed to companies issuing payday loans in the state. Opposition to issuing payday loans in Iowa increases when caucus-goers learn that the average payday loan in the state carries a two-hundred...

This letter urges Chairman Kevin Brady and Ranking Member Sander Levin to reject H.R. 4294, the "SAVERS Act," and support the Department of Labor's (DoL) effort to strengthen retirement income security for working families and retirees. Far from being a pro-retirement security alternative to DoL rulemaking, the legislation would weaken the already inadequate protections afforded by current outdated regulations.

The organizations represented on this sign-on letter asked President Obama to oppose any FY 2017 appropriations bills which include inappropriate ideological policy riders. Appropriations bills have been used before to undermine essential safeguards through "policy riders" – provisions that address extraneous policy issues, and are slipped into appropriations bills to win approval as part of must-pass funding legislation. Last year, hundreds of these policy provisions were proposed as a part of the omnibus process, and in this year's budget process some members of Congress have already started...

This letter to Chairman Pete Sessions and Ranking Member Louise Slaughter urges a strong opposition to H.R. 766, the Financial Institution Customer Protection Act of 2015, introduced by Representative Luetkemeyer. The bill will hamper critical Department of Justice and banking regulator efforts to detect fraud and money laundering, putting consumers and financial institutions at risk of serious financial loss. It is troubling that the House Committee on Financial Services reported out H.R. 766 in July 2015 and that the bill is now under consideration in the Committee on Rules even after a...

As strong supporters of the Department of Labor's (DoL) effort to strengthen retirement income security for working families and retirees, the undersigned on this letter urge the rejection of H.R. 4293, the "Affordable Retirement Advice Protection Act." Far from being a pro-retirement security alternative to DoL rulemaking, the legislation would weaken the already inadequate protections afforded by current outdated regulations. It is a faulty premise that an alternative to the DoL rule is necessary. The DoL's proposed rule offers a balanced approach that expands the range of advisory services...

Public Opinion Strategies conducted a survey of 500 likely voters in Michigan. The survey was conducted December 17-20, 2015 and has a margin of error of +4.3.8% in 95 out of 100 cases. Three hundred (300) interviews were conducted with landline respondents and 200 interviews were conducted with cell phone respondents. Key findings included: There is clear opposition to payday loan lending in Michigan. Opposition to payday loans increases significantly when voters learn that the typical Michigan loan carries three hundred sixty-nine percent annual interest. There is also overwhelming...

The Center for Responsible Lending1 submits this comment to provide additional context about the consumer installment loan market, in particular to highlight issues unaddressed by the proposed settlement with One Main and Springleaf. In this letter, the undersigned organizations bring to your attention three areas of concern that the settlement did not address, but which have a significant impact on borrowers: The high incidence of repeat refinancing in the industry The sale of ancillary products such as credit insurance that significantly increase the cost of installment loans while providing...

The Center for Responsible Lending submits this comment to provide additional context about the consumer installment loan market, in particular to highlight issues unaddressed by the proposed settlement with One Main and Springleaf. In this letter, the undersigned organizations bring to your attention three areas of concern that the settlement did not address, but which have a significant impact on borrowers: The high incidence of repeat refinancing in the industry The sale of ancillary products such as credit insurance that significantly increase the cost of installment loans while providing...

The 40 undersigned organizations oppose inclusion in any criminal justice reform package of "mens rea" (state of mind) provisions that would make it harder for prosecutors to criminally prosecute companies and corporate executives that engage in criminal wrongdoing. Specifically, there are various mens rea proposals, including mens rea legislation proposed in the Senate, that are premised on the belief that our criminal laws are in need of a new, overarching set of standards relating to mens rea. These proposals would likely make it far harder to prosecute corporate crime by overturning the...

On behalf of our millions of members and supporters nationwide, these 45 groups urge the opposition of the so-called "Sunshine for Regulatory Decrees and Settlements Act of 2015" (H.R. 712), which would undermine citizen enforcement of our laws and impede the resolution of consumer protection, anti-discrimination, environmental protection, and other important cases before our federal courts. H.R. 712 targets consent decrees and settlement agreements involving congressionally mandated federal agency actions. These agency actions in many instances have the purpose of protecting civil rights...