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Adding Eligibility for First-Generation Homebuyers to the GSE Affordable Housing Programs

Two vital elements of social and economic mobility are to increase the homeownership rate by enabling more non-homeowners to become first-time homebuyers and reduce the racial disparities in homeownership rates caused in large part by deliberate discriminatory policies and practices. The Government Sponsored Enterprises (GSEs) have the ability to improve both through their affordable housing goals and lending programs. The National Fair Housing Alliance (NFHA) and Center for Responsible Lending (CRL) believe that the Federal Housing Finance Agency (FHFA) should expand the eligibility of the...

Buy Now, Pay Later: No Free Pass from Consumer Protections

The exploding market of Buy Now Pay Later (BNPL) credit demands the same level of oversight that we give to credit cards. BNPL can help some borrowers spread out their payments, but entails real risks and costs, which is not clear in advertisements highlighting interest-free payments and “no impact” on credit scores. Regulation is necessary to protect consumers from hidden harms and costs to promote true financial inclusion. Online and in-store retailers now commonly offer BNPL plans, which allow consumers to make purchases in installments, typically four payments over six weeks. Lenders...

Banks, Credit Unions and Consumer Groups Urge Congress to Close the Industrial Loan Company Loophole

A broad coalition of bank and credit union associations and consumer organizations submitted a letter to the U.S. House Committee on Financial Services urging passage of the bipartisan Close the ILC Loophole Act. The bill would help prevent more companies from running what is essentially a bank without the necessary regulatory oversight.

Income-Share Agreements Burden Students with Unfair Terms and Unforeseen Costs

“Income-share agreements,” or ISAs, fund a portion of educational costs in exchange for a percentage of a student’s earnings over time. Many ISA providers continue to argue that their products are not loans even though they lend money and subsequently require repayment, employing an old and predatory tactic that loan providers use to evade consumer protection guardrails. In fact, ISAs are simply high-cost loans that currently lack even the protections afforded to private student loans, which themselves are a worse option than federal student loans for most borrowers. The high cost of ISAs...

CFPB Should Treat 'Buy Now, Pay Later' Products Like Credit Cards and Protect Consumers from Harmful Practices.

In response to the Request for Comments issued by the Consumer Financial Protection Bureau, the Center for Responsible Lending, the Consumer Federation of America, and the National Consumer Law Center (on behalf of its low-income clients) offer joint recommendations for further guidance and monitoring of the growing Buy-Now-Pay-Later market overall, which are specific to the "pay-in-four" model. Our comment covers substantial background of the BNPL market; considerations based on current consumer protection laws, and concerns we hope the Bureau, within its authority, will address.

77 Groups Urge the CFPB to Supervise the 'Buy Now, Pay Later' Market

The group letter begins: The undersigned 77 consumer, housing, civil rights, legal services, faith, community, small business, student borrower, and public interest organizations appreciate the opportunity to comment on the CFPB’s inquiry into Buy Now, Pay Later (BNPL) credit products that are proliferating across market areas. We welcome the CFPB’s recent inquiry into Affirm, Afterpay, Klarna, PayPal, and Zip, however we remain alarmed by the lack of regulation of this exploding consumer credit product market. We urge the CFPB to view BNPL products as credit cards covered by the Truth in...

APR Matters: Allows True Comparison; Reveals Astronomical Cost of Payday Loans

Payday lenders often describe the cost of their loans in terms of fees or simple interest rates. Responsible lenders readily disclose the APR on their loans, aligned with the Truth in Lending Act (TILA). They are not afraid to let their customers compare the costs of their loans to other loans in the market. Tellingly, payday lenders often object to having to disclose the APR of their loans. Why APR Matters Payday lenders do not like disclosing APR for two reasons. One, it allows a true comparison of the cost with other forms of credit, even those that are short-term like a credit card advance...

Amicus Brief: North Carolina Supreme Court - Townes v. Portfolio Recovery Associates (PRA)

The Center for Responsible Lending, Legal Aid of North Carolina, North Carolina Justice Center, National Association of Consumer Advocates, Charlotte Center for Legal Advocacy, Financial Protection Law Center and Pisgah Legal Services partnered to filed this amicus brief in the North Carolina Supreme Court in Townes v. Portfolio Recovery Associates (PRA). Townes v. PRA is principally about the interpretation of CEPA, NC’s consumer protection statute, and its requirement that debt buyers to produce “itemized accounting” of alleged debts. Plaintiff Ms. Townes is advocating for a bare minimum...

Protect Against Abusive Debt Collection: Working Families Need Wage Protection and a Chance to Save

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...

Credit Bureaus Must Take Action To Correct Credit Report Problems for Transgender and Nonbinary Consumers

145 organizations sent a letter to the “Big Three” credit bureaus (Equifax, Experian, and Transunion) and to the Consumer Data Industry Association (CDIA), the trade association that represents them, urging them to take needed actions to correct credit report problems for transgender and nonbinary consumers.

Coalition Urges SBA and Congress to Fix PPP Forgiveness Rules Unfairly Penalizing Microbusinesses

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...

One Door Closes & Others Remain: Institutional Loans and the 90/10 Formula

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...

Millions of Student Loan Borrowers Need Overdue Income-Driven Repayment (IDR) Reforms

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 Wage Access: States Should Regulate As Credit, Protect Consumers

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.

FDIC Must Stop Banks from Fronting for Predatory Lenders

With a new chairman taking the helm of the Federal Deposit Insurance Corporation (FDIC), the Center for Responsible Lending joined with more than a dozen other organizations in calling for the FDIC to "stop permitting its supervised institutions to front for predatory lenders evading state interest rate limits."

Data Point: California Appeals Court Ruling Affirms Regulator’s Authority to Curb Bail Industry Abuses

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: History of Abusive Debt Collection Practices

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...

Restoring the Promise of Income-Driven Repayment: An IDR Waiver Program Proposal

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.

Comment to CFPB from Broad Coalition Urges Robust Data Reporting Requirements for Small Businesses

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...

Comment to the California DFPI on Proposed Rulemaking to Require Registration and Reporting for Wage-Based Advances

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...

Organizations write to CFPB on Underregulated Fintech Consumer Credit Products

Letter to the CFPB from 79 consumer, housing, civil rights, legal services, faith, community, small business, and financial organizations groups regarding supervision and enforcement of fintech products and fee models that threaten to evade credit, consumer protection, and fair lending laws.

Advocates Outline a Path Forward for California to Rein in Shadow Student Debt

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...
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