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Comparing Dual Track Foreclosure Restrictions

Dual tracking is the servicer practice of simultaneously pursuing loan modifications and foreclosure proceedings. This chart offers a side-by-side comparison and analysis of how the National Mortgage Settlement, the California Homeowner Bill of Rights, and related rules from the Consumer Financial Protection Bureau have each taken steps towards eliminating this practice. The comparison includes variances in rule applications, borrower outreach requirements, denial notices, and more.

Minority Homeownership Study Has Flawed Methodology and Conclusions

The Center for Responsible Lending responds to a recent National Bureau of Economic Research working paper "The Vulnerability of Minority Homeowners in the Housing Boom and Bust," outlining flaws in the paper's analysis and methodology. Most importantly, CRL disputes the authors' conclusions that disparate default rates should call into question the value of homeownership in addressing the racial wealth gap.

Comparing Dual Track Foreclosure Restrictions

Dual tracking is the servicer practice of simultaneously pursuing loan modifications and foreclosure proceedings. This chart offers a side-by-side comparison and analysis of how the National Mortgage Settlement, the California Homeowner Bill of Rights, and related rules from the Consumer Financial Protection Bureau have each taken steps towards eliminating this practice. The comparison includes variances in rule applications, borrower outreach requirements, denial notices, and more.

Advocates Support Proposed Restrictions on Bank Payday Lending

We write to thank the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) for the proposed guidance addressing bank payday lending, particularly the underwriting requirements and limits on repeat loans. These critical provisions address a central problem with payday lending: lenders’ failure to verify the borrower’s ability to repay the loan, and meet other expenses, without reborrowing, leading to a destructive cycle of repeat loans that trap borrowers in long-term debt. This proposed guidance is urgently needed...

HR 1077 Would Weaken Mortgage Reforms in Dodd-Frank

A key mortgage reform included in the Dodd-Frank Wall Street Reform and Consumer Protection Act is at risk of being weakened by new legislation submitted during the 113th Congress. House bill H.R. 1077 would create loopholes in the definition of "Qualified Mortgage" and, as a result, allow higher-fee mortgages to improperly gain Qualified Mortgage status. The Qualified Mortgage designation is intended to benefit borrowers by restricting these mortgages from having risky features such as high origination fees. This fact sheet highlights the fees and loopholes that would hurt America's economy...

All Federal Credit Unions Should Shun Payday Lending

Should federally-insured credit unions push payday loans with triple-digit interest rates? CRL and the National Consumer Law Center (NCLC) say no, urging the National Credit Union Administration (NCUA) to stop its members from making these types of predatory loans. Most credit unions conduct responsible lending that does not include payday-type loans. However, NCLC has identified nine federal credit unions that offer short-term loans with triple-digit rates. These credit unions either make the loans directly or have an arrangement with a third party that uses the credit union's name and makes...

Closing the Gaps: What States Should Do to Protect Homeowners From Foreclosure

This brief, co-authored by CRL and Consumers Union, examines recent legal and regulatory efforts to help troubled homeowners avoid foreclosure. These include rules by the Consumer Financial Protection Bureau to standardize how servicers act and communicate with homeowners, the National Mortgage Settlement negotiated with major servicers by 49 state Attorneys General, California's Homeowner Bill of Rights, and other state laws. The brief then recommends ways for state policymakers to close gaps in these efforts to prevent unnecessary foreclosures.

Senate Bill 515 "Reforming Payday Loans"

California payday loan borrowers get caught in a cycle of repeat borrowing of 459% Annual Percentage Rate (APR) loans. Reforms are necessary to ensure that payday loans serve their advertised purpose and better protect consumers. SB 515 proposes a series of reforms to allow payday loans to better serve their advertised purpose while making the loans safer for consumers. Read the bill summary >>

CRL Strongly Supports SB 515 Reforming Payday Loans

SB 515 includes three principal reforms California payday loans: it caps the number of payday loans per borrower at four per year; extends the minimum term of a payday loan, so that borrowers will have more time to accumulate the amounts necessary to repay it; and requires all lenders to apply standardized underwriting guidelines to ensure that borrowers have a reasonable ability to repay their loans.

Triple-Digit Danger: Bank Payday Lending Persists

Banks pitch payday loans as short-term borrowing that allows their customers to deal with a financial emergency, repay the loan, and move on. In fact, CRL's research shows that their triple-digit interest rate loans trap borrowers in a long-term cycle of repeat loans. Read the full report Read the summary Banks continue to claim that their payday products are intended for short-term emergencies, but this report shows that short-term loans are not typical. Although some participating banks have made small, recent changes in the product, bank payday loans are continuing to trap borrowers in high...

Analysis of the Report of the Monitor of the National Mortgage Settlement

The Monitor of the National Mortgage Settlement recently detailed progress on the $20 billion obligation of the nation's five largest mortgage servicers, under their agreement with 49 state Attorneys General and the Administration. This report, Ongoing Implementation, reported on efforts made over a 10-month period, March 1, 2012 to December 31, 2012, towards home retention, loan modifications, and other assistance. In this policy brief, CRL offers an independent analysis of the Monitor's findings and also poses remaining questions on issues not yet addressed.

Renewed Call for Federal Action Against Bank Payday Loans

Dear Chairman Bernanke, Director Cordray, Director Gruenberg, and Comptroller Curry: One year ago, we wrote to urge the federal regulators of our nation's banks to take immediate action to stop banks from making unaffordable, high-cost payday loans. We were encouraged by the FDIC's May letter indicating that it was deeply concerned and was investigating the practice, and we have also been encouraged that the OCC has not finalized the guidance it proposed in 2011 that would have essentially legitimized the practice. But we are also concerned that a year has passed without decisive regulatory...

State Actions Still Needed to Prevent Unnecessary Foreclosures

Joint Recommendations from CRL and Consumers Union States have yet to recover from the foreclosure crisis that has stripped trillions of dollars from homeowners and devastated local communities across the nation. Industry analysts estimate that 6 million borrowers remain at risk of foreclosure. States are in a strong position to prevent unnecessary foreclosures, stabilize local housing markets and protect homeowners from mortgage servicing abuses. Through practical enhancements to the standards set by the Consumer Financial Protection Bureau (CFPB) and California's Homeowner Bill of Rights...

Driven to Disaster: Car-Title Lending and Its Impact on Consumers

Joint research from CRL and the Consumer Federation of America finds that car-title loans—small-dollar loans secured by the title to a vehicle owned outright—cost U.S. consumers $3.6 billion a year in interest on $1.6 billion in loans. Read the Full Report Read the Executive Summary These products share many of payday loans' predatory features: triple-digit interest rates, balloon payments at the end of the loan's term, and—critically—a failure by the lender to evaluate a borrower's ability to repay. Car-title loans also produce the same effect that payday loans do: A debt trap that leaves too...

How Payday Lending by Banks Violates Safety & Soundness Standards

Applying safety and soundness standards to bank payday loan products follows longstanding principles and policy of the prudential regulators. Consistently, the prudential regulators, including the OCC, FDIC and the Federal Reserve, have addressed problems with a variety of consumer lending products by citing not only consumer protection concerns, but also safety and soundness concerns, even when those products are very profitable for the bank. As discussed further in this memo, bank payday lending shares key troubling characteristics of all the products addressed above and should, likewise, be...

CRL Comment to CFPB on Ability to Repay Standards under the Truth in Lending Act (Regulation Z)

The Center for American Progress, Center for Responsible Lending, Consumer Federation of America and the National Council of LaRaza respond to the Consumer Financial Protection Bureau proposal on the Ability to Repay Standards. The allies offered specific practices to ensure affordable access to mortgage credit. Two specific issues formed the crux of their concerns: How mortgage lending compensation is defined and preserving lending programs that offer a gateway to safe and affordable credit. The mortgage compensation concerns heavily focus on yield spread premiums (YSPs).

Comments to the Consumer Financial Protection Bureau RE: Ability to Repay Standards under the Truth in Lending Act (Regulation Z)

CRL and allied organizations maintain that CFPB's proposal addresses two issues critical to the future of safe, sustainable, and affordable access to mortgage credit. First, it considers how to define compensation for the purpose of calculating the points and fees cap contained in the qualified mortgage definition. Second, it proposes a series of exemptions for specialized lending programs and financial institutions that play an important role in ensuring broad access to safe and affordable credit. This comment letter discusses both of these aspects of the concurrent proposal.

CRL Response to CoreLogic Analysis of Qualified Mortgage (QM) Standards

A recent CoreLogic report ( The Mortgage Market Impact of Qualified Mortgage Regulation) asserts that 48 percent of the mortgage market would not qualify as a "safe loan" under new Qualified Mortgage (QM) guidelines. CRL's review of this study finds that CoreLogic's model unnecessarily excludes certain categories of loans and makes broad (and possibly unwarranted) assumptions about the expiration of the GSE exemption for QM loans.

CRL tells CFPB the CARD Act Works, Encourages Risk-based Pricing

This is CRL's comment to the CFPB in response to the Consumer Financial Protection Bureau's Request for Information Regarding Credit Card Market. In this response, CRL argues that the Credit CARD Act of 2009 has made pricing clearer without restricting credit, raising its cost or curbing the ability of card issuers to price for risk. Contrary to curbing risk-based pricing, the CARD Act encourages risk-based pricing.
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