A new policy brief released today by the Center for Responsible Lending provides a state-by-state snapshot showing predatory payday and car title lenders increasingly moving into installment loans. The lenders are continuing to offer unsafe loans with excessive interest rates, which are carefully designed to trap borrowers in a cycle of debt they cannot escape, and actively seeking to expand...
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The 2015 NC General Assembly adjourned yesterday, months after we first expected them to wrap-up their session. They will reconvene for the short session on April 25, 2016. Because of your calls and letters, three very dangerous bills did not pass: Senate Bill 681, which would have legalized 80 to 125% loans, never even got a committee hearing, House Bill...
This comment was filed in response to the Department of the Treasury’s request for information on marketplace lending. Our history of advocacy for fair lending practices, and against unfair ones, is the lens through which we focus these comments, where we emphasize: Online marketplace loans must comply with applicable state law Underwriting for ability-to-repay, based on income and expenses, should...
The 2015 NC General Assembly adjourned yesterday, months after we first expected them to wrap-up their session. They will reconvene for the short session on April 25, 2016. Because of your calls and letters, three very dangerous bills did not pass: Senate Bill 681, which would have legalized 80 to 125% loans, never even got a committee hearing, House Bill...
The 2014 mortgage data submitted by lenders under the Home Mortgage Disclosure Act (HMDA) reflects a slowly recovering mortgage market, but one that troublingly continues to under-serve important market segments. The implementation of federal mortgage underwriting standards (known as Ability-to-Repay or "ATR" and the Qualified Mortgage rule or "QM") in early 2014 did not cause a departure from mortgage lending...
See details below about 2015 NC General Assembly bills: Senate budget bill would repeal State Fair Housing Act Bill to legalize 80 to 125% loans still stalled Bill to roll back debt collection protections also stalled Ratified bill reduces protections against harassing calls Wage garnishment put into study committee bill Bills to reduce protections against mortgage broker abuses have not...
On July 30, 2015, the Center for Responsible Lending joined Higher Ed Not Debt, Consumers Union, Consumer Action, Generation Progress, National Consumer Law Center, Student Debt Crisis, United States Student Association, Veterans for Education Success, and the Woodstock Institute in sending this letter to Debbie Matz, Chairman of the National Credit Union Administration. The letter concerns private student loans to...
H.R. 1737 would frustrate efforts to crack down on discriminatory auto lending practices. The bill places unnecessary restrictions on CFPB oversight of auto lending, including interest rate markups that cost consumers tens of billions of dollars and have been found to violate fair lending practices through a differential impact on minority purchasers of automobiles. The restrictions in this bill do...
H.R. 1210 would weaken the CFPB's Ability-to-Repay standards for mortgage loans. These standards are designed to protect consumers against the kind of toxic and exploitative mortgage loans which helped cause the financial crisis and led to massive consumer losses, and should not be weakened. The bill would allow depository institutions that hold a loan in portfolio to receive a legal...
HUD/FHA is proposing to amend language on their certification forms where lenders certify that a loan is eligible for FHA financing (insurance). We believe the proposed language is a step in the right direction, but we offer additional suggestions. The components of our recommended framework to FHA include providing a certification that includes provisions for all of the following: The...
On July 13 CRL submitted this comment letter detailing its concerns with the state of student loan servicing.
Certification plays an important role in protecting the health of the Federal Housing Administration's (FHA) mutual mortgage insurance fund so that millions of Americans—many of whom are first-time buyers, come from low and moderate-income backgrounds, or purchase homes in communities of color—can continue to become successful homeowners. Certification also serves another equally important purpose by requiring lenders to certify that...
CRL joined a sign on letter with over 100 consumer, student, education, civil rights, labor, and veterans groups detailing their concerns about the lack of oversight of student loan servicing.
From the letter: We, the undersigned organizations, are based in states throughout the U.S. that ban payday lending and other types of high-cost, predatory small-dollar loans. We write to you from our perspectives as military associations, social service providers, faith leaders, affordable housing agencies, legal service providers, labor organizers, and civil rights advocates. Read the entire letter. (PDF)
Comment of the Center for Responsible Lending and the National Consumer Law Center (on behalf of its low income clients) on the Proposed Amendments to the Cash Management Rule, 34 C.F.R. Part 668. Also see broad coalition comments to the Department of Education
A letter to the president of the National Automobile Dealers Association, calling on him to release the data showing the amount customers who finance cars pay in dealer interest rate markup.
Today, the Center for Responsible Lending (CRL) filed a public comment on urgently needed rules proposed by the California Department of Business Oversight (DBO) that would require payday lenders to follow California law by prohibiting the use of electronic transfers and debit cards in payday transactions. The rules would also create a new real-time electronic database to enforce existing law...
State of Lending provides an across-the-board survey of financial products that Americans use to handle everyday transactions, buy homes and automobiles, and build savings and wealth. The report outlines predatory lending practices in various fields of consumer lending, and explains why protecting fair, affordable access to credit is vital for both consumers and the U.S. economy. The report also describes...
In this final chapter of The State of Lending in America and its Impact on U.S. Households series, we demonstrate the cumulative high costs of lending abuses, discuss lessons learned from efforts to address predatory lending, and suggest steps for further action. This chapter comprises the following sections: Lending Abuses and Their Costs describes how various types of lending abuses...
On May 12, 2015, the Senate Committee on Banking, Housing, and Urban Affairs' Chairman, Senator Richard Shelby (R-AL), introduced a discussion draft of "The Financial Regulatory Improvement Act of 2015" ("Chairman's Draft"). The proposal comes at a time when offering community banks relief from recently created laws and regulations for the mortgage market is dominating some discussions about Congressional efforts...
CRL, The Public Good Law Center, and the National Association of Consumer Advocates filed an amicus brief supporting an appeal by plaintiffs asserting that loans made by the payday lender CashCall were unconscionable and violated California's Unfair Competition Law. Courts and the common law have long recognized that excessive interest rates and prices are unconscionable and therefore "unfair" and "unlawful."...
The Center for Responsible Lending applauds the CFPB for its continued focus on student loan servicing. Good loan servicing benefits both the borrower and the lender by helping borrowers successfully pay down their loans. As the CFPB holds a field hearing on student loan servicing today in Milwaukee, we offer seven ideas for a fair student loan servicing system: Prevent...
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. Download a summary of the full report. 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...
A recent blog on the Washington Post site took Senator Elizabeth Warren to task for citing a statistic in a report from the Center for Responsible Lending (CRL). Our report quantified the amount that consumers pay in auto dealer markups. Auto dealers are paid large bonuses to raise the rate on auto loans above the rate that consumers qualify for...
Testimony by Paul Leonard from the May 6, 2015 Informational Hearing on the Consumer Financial Protection Bureau Rulemaking for Payday, Vehicle Title and Similar Loans before the California Senate Banking Committee. The CFPB aims to cover payday and similar loans under its rule regardless of the provider or channel offering the loans (storefront and online; bank/credit union, non-depository, tribal entity)...