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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 months. Although they are repaid in installment terms, these loans share similar characteristics with other payday and car-title loans: a lack of underwriting; access to a borrower’s bank account or car as security...

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 groups jointly filed a petition for the CFPB to develop a rule that would define larger participants in the market for personal loans so that sizable non-depository lenders would be subject to consistent CFPB supervision...

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 Program (PPP) loans. Read the full letter.

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.

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 45% of used car purchases are financed. Enforcement actions by federal and state consumer protection agencies, as well as private litigation, have highlighted auto dealer practices that exploit the...

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 the pandemic The COVID-19 pandemic forced one-third of student debt borrowers to use savings or credit cards to meet overall expenses The payment pause helped roughly 40 percent of student loan borrowers...

Letter Calls for Fed & OCC to Reject Proposed TD Bank Merger

Amid growing concern about corporate consolidation, the Center for Responsible Lending (CRL) and Americans for Financial Reform Education Fund are leading a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank. Their comment letter points to several reasons why regulators should deny the application, including TD Bank’s exceptionally poor treatment of consumers and an exacerbation of the “too-big-to-fail” problem if the merger is approved. Co-signatories are Alaska PIRG, American...

Testimony: Nadine Chabrier in Opposition of TD Bank Merger with First Horizon Corporation

On August 18, 2022, Nadine Chabrier, senior litigation and policy counsel for the Center for Responsible Lending, provided testimony at a public meeting of the Office of the Comptroller of the Currency (OCC) and the Federal Reserve System on the proposed merger of TD Bank and First Horizon Bank.

Joint Comment Letter on the Community Reinvestment Act Calling for Affordable Credit for Minority-Owned Businesses

The National Coalition for Asian American Community Development (National CAPACD), the Center for Responsible Lending (CRL), and the National Association for Latino Community Asset Builders (NALCAB) are pleased to submit collective recommendations as the Building Back Better for Entrepreneurs of Color partnership to the interagency request for public input regarding the Community Reinvestment Act.

Comment on the Community Reinvestment Act, Notice of Proposed Rulemaking

The Center for Responsible Lending and Center for Community Self-Help applaud the effort of the Agencies to update and modernize the CRA regulations given the massive changes that have taken place in the financial services industry in the more than 25 years since the regulations were last amended. Likewise, we support the overall thrust of the Agencies’ proposal, which provides a much more robust, transparent, and objective framework for conducting CRA evaluations than that provided by current regulations. We offer these comments to respond to some of the questions posed by the NPRM and...

Debt Under Duress: The Economic Impacts of Bail Bonds on San Francisco Bay Area Residents

Nearly 500,000 people are currently detained pretrial in jails around the United States, in part due to high bail amounts set by the judicial system that individuals cannot afford. That is a six-fold increase in the U. S. pretrial population from the 1970s, when it was closer to 83,000 people detained. Bail is money required in exchange for release from jail while one awaits trial. With bail costs rising, it has been difficult for individuals and their loved ones to afford paying a court directly for the full bail amount. Instead, they have increasingly turned to for-profit bail bond companies...

Restoring Income-Driven Repayment

Income-driven repayment (IDR) plans are designed to help borrowers make affordable student loan payments for no more than 20 or 25 years, depending on the type of plan. However, the complexity of these programs has made it notoriously difficult for borrowers to navigate: The application process is lengthy and requires annual re-enrollment; Servicing errors and abusive practices keep low-income borrowers in IDR for too long; Lack of broad forgiveness has kept millions trapped in a cycle of debt. Download to continue reading.

Coalition Letter in Support of Extending and Expanding the PSLF Waiver & IDR Adjustment Student Debt Relief Programs

More than 130 organizations representing students, student loan borrowers, teachers, workers, and consumers have sent a letter calling on the President to extend and expand the PSLF Waiver & IDR Adjustment student debt relief programs.

Amicus Brief: California Superior Court - Opportunity Financial v. Hewlett

On July 8, the Center for Responsible Lending, California Reinvestment Coalition, Consumer Federation of California, National Consumer Law Center, Public Law Center, and UC Berkeley Center for Consumer Law & Economic Justice filed an amicus brief in Los Angeles County (California) Superior Court in Opportunity Financial v. Hewlett. Opportunity Financial v. Hewlett addresses the legality of Opportunity Financial’s “rent-a-bank” scheme, whereby OppFi makes loans in California in excess of the state’s rate caps by laundering those loans through an out-of-state bank that is exempt from state rate...

Adjusting the COVID-19 Flex Mod to Deliver Payment Reduction to More Borrowers in Need

While most homeowners with GSE-backed mortgages have recovered from pandemic-related hardships and reinstated their mortgage, as of June 7, about 1.6% of outstanding GSE borrowers were in a state of nonpayment: about 140,000 GSE-backed loans were in COVID-19 Forbearance, and another roughly 300,000 loans were delinquent outside of forbearance. For those GSE borrowers who were less than 2 months delinquent as of the onset of the pandemic who cannot resume their originally scheduled monthly payments due to ongoing pandemic-related financial hardship, the GSEs offer the COVID-19 Flex Modification...

Consumer Rights Organizations Call on FDIC to Downgrade TAB Bank on its Community Reinvestment Act Exam

From the introduction to 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 low income clients), Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of Transportation Alliance Bank (dba TAB Bank). TAB Bank serves as a rent-a-bank, nominally originating predatory loans at rates up to 189% APR for Duvera Billing Services, dba EasyPay Finance, to help EasyPay evade state...

Testimony: Mike Calhoun on Boom and Bust: Inequality, Homeownership, and the Long-Term Impacts of the Hot Housing Market

On June 29, 2022, Mike Calhoun, CRL's president, testified before the House Committee on Financial Services for a hearing entitle, “Boom and Bust: Inequality, Homeownership, and the Long-Term Impacts of the Hot Housing Market.” His written testimony is available for download. Watch a recording of the hearing:

Resilient But Deeper in Student Debt: Women of Color Faced Greater Hardships Through COVID-19

Women carry about two-thirds of the $1.7 trillion of federal student debt, with Black women more than twice as likely as white men to owe more than $50,000 in undergraduate student loan debt. Women carry about two-thirds of the $1.7 trillion of federal student debt, with Black women more than twice as likely as white men to owe more than $50,000 in undergraduate student loan debt. The COVID-19 crisis has exacerbated the financially unstable positions of many women, furthering gender disparities. The Center for Responsible Lending (CRL) commissioned four focus groups with women who voluntarily...

Broad Coalition of Organizations and Faith Leaders Urge $50K Cancellation of Federal Student Debt by Executive Action

From the introduction to the letter: The undersigned civil rights, student, community, and consumer advocacy organizations, along with faith leaders from across the country, urge you to use the authority of executive action to cancel $50,000 of federal student loan debt per borrower to stimulate the economy, bridge the racial wealth gap, and alleviate the financial suffering of millions of Americans, including Black women. While women carry around two-thirds of student debt, Black women are more than twice as likely as white men to owe more than $50,000 in undergraduate student loan debt.

Comment: Access to Capital Is One of the Greatest Barriers to Success for Minority Entrepreneurs

NALCAB, the National Association for Latino Community Asset Builders, The National Coalition for Asian Pacific American Community Development (CAPACD), and the Center for Responsible Lending (CRL) write in response to the invitation for public comments regarding changes made to the Community Advantage Pilot Program (CA) noticed in the Federal Register on April 29th, 2022. Access to capital is one of the greatest barriers to success for minority entrepreneurs. Since its inception in 2011 CA has successfully expanded access to capital for small businesses located in underserved communities...

500+ Organization Coalition Calls on President Joe Biden to Immediately Cancel Student Debt

A broad coalition of 529 community, civil rights, education, climate, health, consumer, labor, professional, food and farm, and student advocacy organizations wrote a letter to President Biden urging him to strengthen the economy, tackle racial disparities, and provide much-needed relief to help all Americans weather the pandemic and record inflation by using executive authority to cancel federal student debt immediately. Read the full letter.

CRL Student Debt Cancellation HBCU Panel Discussion

The Center for Responsible Lending (CRL) recently hosted a panel discussion to examine the student debt experience of students who attend or who have graduated from Historically Black Colleges and Universities (HBCUs). The group put faces to data as they discuss student debt cancellation and its potential impacts, particularly on people of color. Serving as moderator was Jaylon Herbin, CRL Policy and Outreach Manager and Student Loan Lead. Participants included: Wisdom Cole, NAACP National Director, Youth in College Division; A’Kira Thomas, a third year law student (3L) at NCCU School of Law...

Advocates Urge Auto Repair Chains, Including AAMCO, Meineke, and Midas, To Stop Offering Predatory Loans

A coalition of consumer advocacy groups sent letters to major national auto repair chains AAMCO and Precision Tune Auto Care (Icahn Enterprises), Big O Tires and Midas (TBC Corporation), Grease Monkey (FullSpeed Automotive), JiffyLube, and Meineke (Driven Brands) urging their stores and franchisees to stop offering financing through EasyPay Finance and Utah-based TAB Bank, which issue loans at rates up to 189%, even in states where that rate is illegal.

Necessary Relief: Substantial Cancellation Will Ease the Burden of Unaffordable Student Debt (and Boost the Economy)

The student debt crisis has been building for decades, and millions of families have seen their dreams derailed by unaffordable debt repayment burdens that block their path to financial stability. As college costs rose, students had to take on increasing amounts of debt to pay for higher education. At the same time, state student financial aid offerings were drastically reduced, forcing students and families into long term debt that often grew to be unaffordable over time. Due to longstanding discrimination, students and families of color have less personal, family, and intergenerational...
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