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Coalition Opposes Dangerous Package of Bills Titled the “CFPB Transparency and Accountability Reform Act”

From the introduction to the letter: On behalf of the undersigned national, state, and local organizations, we urge you to oppose the dangerous package of bills titled the “CFPB Transparency and Accountability Reform Act” that threaten the Consumer Financial Protection Bureau’s (CFPB) funding, organizational structure, and its ability to monitor the marketplace by impeding their rulemaking functions. This package would...

Comment in Support of Strengthening the Department of Housing and Urban Development (HUD) Proposed Rule on Affirmatively Furthering Fair Housing

CRL and more than 50 organizations committed to gender justice submitted a comment in support of strengthening the Department of Housing and Urban Development (HUD) Proposed Rule on Affirmatively Furthering Fair Housing, which was published in the Federal Register on February 9, 2023 (HUD Docket No. FR 6250-P-01) (Proposed Rule).

Adding Fuel to the Fire: OppFi Hurts, Does Not Help, Borrowers’ Credit Health

Opportunity Financial, also known as OppFi, is a consumer lending company based in Chicago, Illinois that offers personal installment loans. Although OppFi’s stated mission is to “empower everyday consumers to rebuild their financial health,” OppFi is a legacy subprime lender. The company uses a rent-a-bank scheme to evade consumer protections and charge customers triple-digit interest rates on its personal installment...

Burned Borrowers: A Look at the Experiences of OppFi Customers

Opportunity Financial, also known as OppFi, is a consumer lending company based in Chicago, Illinois that offers personal installment loans. Their marketing suggests they are providing an essential service to the credit and income constrained; their products, however, carry triple-digit Annual Percentage Rates (APRs). Public filings reveal a business model built around high levels of delinquency and default. According to...

Letter Submitted to Subcommittee on Higher Education and Workforce Development hearing on the Implications of Biden's Student Loan Policies

CRL submitted this letter for the record on the Subcommittee on Higher Education and Workforce Development hearing entitled, "Breaking the System: Examining the Implications of Biden's Student Loan Policies for Students and Taxpayers."

Allow the CFPB’s Final 1071 Rulemaking to Proceed without Delay

National CAPACD, NALCAB, and the Center for Responsible Lending submitted this letter to support the Consumer Financial Protection Bureau’s (CFPB) final Section 1071 regulation which will improve relationship banking by creating a robust and comprehensive data collection regime that helps ensure that small business lending is fair and accessible to entrepreneurs from all communities in the United States.

Consumers Groups Call On the FTC to Regulate Junk Fees

In response to a Federal Trade Commission (FTC) notice that it intends to issue regulation, CRL joined a coalition of consumer groups in calling for FTC action to rein-in junk fees. Among other topics, this comment letter highlights a CRL report on installment loan companies that would tack on credit insurance and “automobile club memberships” – charges that meet multiple...

Coalition Comments to FDIC Regarding Community Reinvestment Act Examination of First Electronic Bank

Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low- income clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submitted comments for the Community Reinvestment Act (CRA) examination of First Electronic Bank. First Electronic Bank helps at least two nonbank lenders...

Comments to FDIC from Coalition on Community Reinvestment Act Examination of Rent-a-Bank FinWise Bank

From the comment: Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its lowincome clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of FinWise Bank. FinWise Bank helps several nonbank...

Earned Wage Advance is Credit (In Focus Series #3)

Earned Wage Advance (EWA) providers market a means for workers to access their wages before payday, usually for a fee. In reality, there are two very different types of products that are marketed as EWA, one of which—sometimes called “faux EWA”— is simply a payday loan dressed up in “fintech” marketing. While low-wage workers can benefit from true EWA programs...

CRL Testimony for "Consumer Financial Protection Bureau: Ripe for Reform" Hearing

The Center for Responsible Lending submitted a letter for the record on the House Committee on Financial Services’ Subcommittee on Financial Institutions and Monetary Policy hearing entitled, “Consumer Financial Protection Bureau: Ripe for Reform.” The letter details the importance of the CFPB and draws on new data from Republican polling firm Chesapeake Beach Consulting and Democratic firm Lake Research Partners...

Consumer and Civil Rights Groups Urge OCC to Reform Inequitable Overdraft Programs

The following organizations signed on to a letter to Michael Hsu, Acting Comptroller of the Office of the Comptroller of the Currency, urging him to act and ensure that OCC-supervised banks make necessary reforms to their inequitable overdraft programs. Accountable.US Americans for Financial Reform Education Fund California Reinvestment Coalition Center for Responsible Lending Consumer Action Consumer Federation of America Consumer...

Payday Lending Supporters Promote Flawed Analysis to Justify Predatory Interest Rates

A report released in January of 2023 attempts to provide cover for the predatory practices of payday lenders, who charge average 400% annual interest on loans that routinely create a long-term cycle of debt that sends borrowers into deep financial insecurity. The Consumer Financial Protection Bureau (CFPB) found that 75% of payday lender fees are collected from borrowers with 10...

CRL & NCLC Letter to the VA Regarding Loss-Mitigation Options for Guaranteed Loans

In response to the questions posed in the VA’s October 17, 2022 Advance Notice of Proposed Rulemaking, the National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending urge VA to expand the opportunities available to help veteran borrowers avoid foreclosure. The mortgage relief options available for veteran borrowers should not be less favorable...

Upsold and Weighed Down: An Analysis of a Subset of Supervised Installment Lending in Colorado

Previous research by the Center for Responsible Lending (CRL) has revealed the harms associated with high-cost installment loans, which are often marketed to subprime borrowers and have annual percentage rates of interest (APRs) in excess of 36%. This paper explores a different segment of the installment loan market: loans made by consumer finance companies with rates at or below 36%...

Testimony: Mitria Spotser on the VA Housing Loan Forever Act of 2022

On December 14th, Mitria Spotser, a consultant for the Center for Responsible Lending (CRL) testified before the House Committee on Veterans Affairs hearing on a discussion draft bill, the VA Housing Loan Forever Act of 2022. Her written testimony is available for download and the recorded video is available below.

Veterans Affairs Loan Refund Program

From the letter to the U.S. Department of Veterans Affairs (VA): The dramatic increase in interest rates since the turn of the year has significantly reduced the effectiveness of VA’s current loan modification program. As a result, an additional loss mitigation option is needed to help veterans who cannot afford to resume their originally scheduled mortgage payments and are in...

Poll Results on Bipartisan Support of the Ongoing Mission of the CFPB to Regulate the Financial Industry and Protect Consumers

New data from the bipartisan polling team Lake Research Partners and Chesapeake Beach Consultingi shows that voters across the political spectrum overwhelmingly support the ongoing mission of the Consumer Financial Protection Bureau (CFPB) to regulate the financial industry and protect consumers. The new findings are consistent with over 10 years of opinion research demonstrating strong public support for the agency’s...

Comment: CRL and Self-Help Support the CDFI Fund’s Adoption of Meaningful Consumer Protections in CDFI Certification Application

The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund strongly support the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. In November 2020, CRL and Self-Help urged the Fund to adopt several critical consumer protections in the Fund’s certification application. We are...

Coalition Applauds CDFI Fund’s Focus on Community Development

A broad coalition of consumer groups filed comments supporting the CDFI Fund’s changes to the application for CDFI certification. In recent years, many harmful financial products have been pushed on underserved communities in the name of “access to credit” and “financial inclusion.” Most CDFIs stay away from these harmful products and are true to their mission but far too many...

Payment Supplement: A Loss Mitigation Option to Provide Payment Relief for FHA Loans in a High Interest Rate Environment

As of the end of August 2022, 350,000 FHA borrowers were seriously delinquent. Some of these borrowers will regain their financial footing, cure their delinquency, and resume their monthly payments, while others will sell their homes. The remainder will need a reduction in their monthly payment to an affordable level to remain in their home. However, the combination of the...

CFPB Should Update Mortgage Regulations to Reduce Unnecessary Foreclosures and Reduce the Racial Wealth Gap

The National Consumer Law Center (on behalf of its low-income clients), the Center for Responsible Lending, and the National Housing Law Project submitted this comment to the Consumer Financial Protection Bureau in response to a request for information regarding mortgage refinances and forbearances.
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