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Debt collectors, including debt buyers, have weaponized the courts and frequently sue the wrong consumer for the wrong amount. Armed with a judgment, they use wage garnishment orders and bank account levies to seize money from families who are the least able to afford it. Research shows that nearly half of all Americans do not have enough savings to cover three to six months’ worth of living expenses, yet that is what people need to ensure that they can provide for their families. CRL is calling on the federal government to protect $12,000 in people’s bank accounts from being levied, per adult...

CRL and more than 50 community development, civil rights and small business groups, including National Urban League, National Association for Latino Community Asset Builders, UnidosUS and National Coalition for Asian Pacific American Community Development are urging SBA and Congress to fix the Paycheck Protection Program’s current forgiveness rules so that microbusinesses can receive full forgiveness of their PPP loans. Urgent recommendations in the letter include: Eliminate denials of loan forgiveness due to sudden changes in rules that were imposed without advance notice, both for business...

The “90/10 Rule” is meant to ensure that for-profit schools are, in fact, competitive in the marketplace and are not relying only on taxpayers to survive. In other words, the rule is based on the principle that a viable educational program should be funded in part by students or employers who are willing to pay cash to invest in career training for themselves or their employees, respectively. Although a small percentage of proprietary schools have failed the 90/10 test in recent years, between 11 and 20 percent of schools derive over 85 percent of their revenues from Title IV sources. Because...

Download the letter to Secretary Miguel Cardona from 104 organizations representing students, student loan borrowers, teachers, workers, civil rights, veterans, people of faith, and consumers urging him to deliver on the promise of income-driven repayment (IDR) programs for federal student loan borrowers through the creation of an IDR restoration project, or an IDR waiver.

Earned or Early Wage Access (EWA) products offer workers access to their wages before payday, usually for a fee. While low-wage workers can benefit from EWA programs that are properly designed and regulated, they can instead be harmed when products are allowed into the marketplace without guardrails keeping their use and cost within reasonable bounds. States should regulate all EWA products as credit and require compliance with consumer protections that prevent predatory lending debt traps commonly associated with payday loans.

In a precedent-setting ruling, the California Court of Appeals at the end of 2021 handed down a decision affirming a broad preliminary injunction against a bail bond company called Bad Boys Bail Bonds. The court prohibited the company from collecting on $38 million in debt from cosigners who borrowed money to gain pre-trial release for their loved ones. The order, which stemmed from a historic class action lawsuit filed in 2019 by the Lawyers’ Committee for Civil Rights of the San Francisco Bay Area and Keker, Van Nest and Peters LLP on behalf of cosigners, says bail companies must follow...

Oportun is a California-based financial services provider that is rapidly expanding its reach. In some states, Oportun has announced its loans will be originated by MetaBank, indicating it is employing the “rent-a-bank” scheme, wherein lenders pay a bank with a national charter that is willing to pose as the lender so they can avoid having to comply with state consumer protections. Oportun had applied for a national charter of its own, but withdrew the application amid public scrutiny of its practices. Oportun has secured endorsements from influential Latino organizations in states where it...

Many of the problems that led to the failure of the Public Service Loan Forgiveness (PSLF) program are IDR problems in disguise—such as borrowers being steered into the wrong repayment plan and Family Federal Education Loan (FFEL) servicers failing to tell borrowers of consolidation options. These problems will not be corrected by a solution that only addresses the PSLF program.

The Center for Responsible Lending (CRL), the National Association of Latino Community Asset Builders (NALCAB), and the National Coalition for Asian Pacific American Community Development (National CAPCACD), along with eleven undersigned public interest groups submitted comments to the Consumer Financial Protection Bureau in regards to its proposed rule to implement Section 1071 of the Dodd-Frank Wall Street Reform and Protection Act. The proposed rule will expand the data collection and reporting requirements in the Small Business Lending Market to include women-owned, minority-owned and...

The National Consumer Law Center, on behalf of its low-income clients, the Center for Responsible Lending, and the Consumer Federation of California submitted comments to the Department of Financial Protection and Innovation’s (DFPI) proposed regulation governing the registration and data reporting requirements for certain industries. These comments focused on the proposed registration of providers of wage-based advance providers. In these comments, we first highlight the risks that wage-based advances pose to workers. We then discuss the critical importance of ensuring substantive protections...

In a letter to California’s Department of Financial Protection and Innovation (DFPI), the Student Borrower Protection Center, the Center for Responsible Lending, the Consumer Federation of California, Consumer Reports, the Student Debt Crisis Center, the National Consumer Law Center, NextGen Policy, and Young Invincibles commented on proposed rules for education financing products in California. The letter notes that the DFPI’s draft regulations already mark a substantial step forward in efforts to shine a light on the risky shadow student debt market while pointing to key areas in which the...

From the beginning of the comment letter : The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), Americans for Financial Reform Education Fund, and Consumer Federation of America appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan (SDL) Program Application. The comments focus on aspects of the application aimed to ensure that the program is promoting affordable and responsible small dollar loan products. CRL is an affiliate of Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures...

For-profit colleges are big businesses, primarily funded by taxpayers. Many deliver poor instructional quality at high cost, causing a high proportion of students to drop out. Even for those students who do graduate, gainful employment in the field that they trained for is frequently elusive. Both non-completers and graduates bear high burdens of debt relative to their post college earnings and default on that debt in large numbers relative to those students who attended public and private non-profit colleges. Interactive Map Many for-profit students are nontraditional students, making...

The Center for Responsible Lending, the National Community Stabilization Trust (NCST), the Consumer Federation of America, the National Housing Conference, and the Leadership Conference on Civil and Human Rights, appreciate the opportunity to comment on the proposed rule to amend the Enterprise Regulatory Capital Framework (ERCF) by refining the prescribed leverage buffer amount (PLBA) and the credit risk transfer (CRT) securitization rules for Fannie Mae and Freddie Mac (the Government-Sponsored Enterprises (the GSEs)). Overview and Executive Summary We support the Federal Housing Finance...

As Adam Harris writes in his 2021 book, The State Must Provide: Why America’s Colleges Have Always Been Unequal—And How to Set Them Right: “America’s colleges and universities have a dirty open secret: they have never given Black people an equal chance to succeed.” Despite long-standing systemic challenges and the small average size of Historically Black Colleges and Universities (HBCUs), these institutions have an impact significantly greater than one would expect and perform a critical function for Black students. Nationally, HBCUs annually generate more than 130,000 jobs and almost $15...

The $1.7 trillion student debt crisis impacts over 44 million families nationwide, and the burden of student loans falls particularly heavily on Black students because of historical and ongoing systemic racism. While Black families themselves typically have less wealth to draw upon to pay for college due to the racial wealth gap, Historically Black Colleges and Universities (HBCUs) have also been underfunded throughout their histories, compounding the challenges for HBCU students who face financial challenges at both the familial and institutional levels. These challenges often result in...

The $1.7 trillion student debt crisis impacts over 44 million families nationwide, and the burden of student loans falls particularly heavily on Black students because of historical and ongoing systemic racism. While Black families themselves typically have less wealth to draw upon to pay for college due to the racial wealth gap, Historically Black Colleges and Universities (HBCUs) have also been underfunded throughout their histories, compounding the challenges for HBCU students who face financial challenges at both the familial and institutional levels. These challenges often result in...

The $1.7 trillion student debt crisis impacts over 44 million families nationwide, and the burden of student loans falls particularly heavily on Black students because of historical and ongoing systemic racism. While Black families themselves typically have less wealth to draw upon to pay for college due to the racial wealth gap, Historically Black Colleges and Universities (HBCUs) have also been underfunded throughout their histories, compounding the challenges for HBCU students who face financial challenges at both the familial and institutional levels. These challenges often result in...

On October 28, 2021, the Center for Responsible Lending and the United Negro College Fund hosted a virtual discussion highlighting how the COVID-19 crisis has affected Black students nationwide due to our nation’s ongoing systemic racism. The talk highlighted new findings that reveal how the experiences of Black student loan borrowers from Historically Black Colleges and Universities (HBCUs) differ from the experiences of their Black peers at predominately white institutions (PWIs). Panelists drove home the need for $50,000 in across-the-board student loan cancellation and increased HBCU...

Congress cannot miss this once-in-a-generation opportunity to expand homeownership and create racial justice and equity. Targeted DPA is one of the most cost-effective strategies to shrink disparities in wealth and narrow the homeownership gap.1 More than half a million Black and Latino families could become first-generation homeowners thanks to this program even if funded at $30 billion over ten years. In this case, DPA would help 288,208 Black families; 223,649 Latino; 88,000 Native American, Asian American, and Pacific Islander families; and 249,398 white families achieve homeownership.
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