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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...

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...

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...

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...

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...

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.

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...

“Paying from the Grave”: Historically Black Colleges and Universities (HBCU) Alumni and the Burden of Student Loan Debt

More than 44 million people in the United States—roughly one in six adults—collectively hold more than $1.6 trillion in federal student loan debt. Although many Americans are burdened by their student loan debt, borrowers who attended Historically Black Colleges and Universities (HBCUs) have been especially hard hit, due to the impacts of systemic racism on wealth accumulation for families and...

The Protecting Wages of Essential Workers Act of 2022 (Protecting Wages Act)

The Protecting Wages Act will keep more money in the pockets of working people struggling to pay rent and put food on the table, while still allowing the collection industry to collect debts. Protects Enough Wages for Basic Needs From Seizure: Protects $1,000 in disposable earnings per week from being seized for old debts, or 75% of disposable earnings, whichever...

Unsafe Harbor: The Persistent Harms of High-Cost Installment Loans

Over the past decade, the high-cost small-dollar loan market, once dominated by short-term balloon payment payday loans, has seen the rise of high-cost installment loans with longer terms. Payday loans are typically repaid in a lump-sum, usually due in 14-day periods. Installment loans tend to be larger in size and repaid in several installments, typically over a period of several...

Bank and Consumer Groups Petition CFPB for Oversight of Non-bank Personal Loans

The market for personal loans is massive and growing, yet the fintechs and other non-bank lenders who make such loans are not subject to regular oversight by the Consumer Financial Protection Bureau (CFPB), which has “created an unlevel playing field and a large risk to consumers,” write the Consumer Bankers Association (CBA) and the Center for Responsible Lending (CRL). The...

Letter Urging the U.S. Treasury Department and U.S. Small Business Administration to reverse the Good Faith Error Rule of the Paycheck Protection Program

The Center for Responsible Lending (CRL), American Business Immigrant Coalition (ABIC), and more than 20 consumer, civil rights and advocacy groups and lenders, recently submitted a letter urging the U.S. Treasury Department and U.S. Small Business Administration (SBA) to reverse the Good Faith Error Rule that has prevented more than 300,000 small business owners from obtaining forgiveness of Paycheck Protection...

The FTC Must Work to Make the Auto Lending Marketplace Safe from Unfair and Deceptive Trade Practices

Cars are essential for most households in the United States, but access to a safe, affordable vehicle is increasingly limited for many consumers by sharply rising prices, burdensome accompanying debt obligations, and problematic dealer practices. The cost of a vehicle represents such a significant proportion of many American households’ total annual income that over 88% of new car purchases and...

Sign-on Letter to the FTC Addressing Auto Sale Add-ons, Price and Financing Disclosures, Yo-yo sales, and More

Letter signed by 110 national, state, and local consumer, civil rights, legal services, community, public interest organizations, consumer attorneys, and others in comment on the FTC’s Notice of Proposed Rulemaking (NPRM) on the sale, financing, and leasing of motor vehicles by dealers.

Poll Results: Federal Student Loan Payment Pause Helps Borrowers Pay for Basic Needs

Morning Consult conducted a survey, commissioned by Center for Responsible Lending. The poll is presented as a short Powerpoint-style slide deck with key takeaways and charts. Key findings include: Millions struggled to meet their basic needs due to the burden of student debt Low-income borrowers in loan forgiveness programs were more likely to skip meals and face wage garnishment throughout...
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