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Response to the State Corporation Commission’s Order Requesting Additional Comments on Proposed Regulations to Implement Virginia’s New Student Loan Borrower Bill of Rights

From the introduction of the letter: The undersigned organizations representing Virginia consumers, students, student loan borrowers, and educators submit this comment in response to the State Corporation Commission’s (the “Commission”) July 9, 2021, Order Requesting Additional Comments (the “Order”) on proposed regulations to implement Virginia’s new Student Borrower Bill of Rights. The Commission specifically requested comments further addressing whether the...

Oportun's Abusive Lending Practices Harm Latino and Immigrant Borrowers

From the coalition letter to Michael J. Hsu, acting comptroller of the currency, Office of the Comptroller of the Currency: We the undersigned community, consumer, and civil rights organizations write to express serious concerns about Oportun’s application to the Office of the Comptroller of the Currency (OCC) for a national bank charter. Exactly one year ago, Oportun made headlines for...

Testimony: Protecting Americans from Debt Traps by Extending the Military’s 36% Interest Rate Cap to Everyone

On July 29, 2021, Ashley Harrington testified before the Senate Committee on Banking, Housing and Urban Affairs hearing on "Protecting Americans from Debt Traps by Extending the Military's 36% Interest Rate Cap to Everyone." Her written testimony as well as her oral remarks are available for download. Watch the recorded hearing:

Overdraft Fees Cause Financial Exclusion; Policymakers Must Act

This statement was entered for the record for the July 21, 2021 hearing on “Banking the Unbanked: Exploring Private and Public Efforts to Expand Access to the Financial System” before the U.S. House Committee on Financial Services, Subcommittee on Consumer Protection and Financial Institutions. Download the testimony above or view a webcast of this hearing.

Comments on Restoring Affirmatively Furthering Fair Housing Definitions and Certifications

The undersigned fair housing, affordable housing and civil rights organizations write to you in response to the proposed Interim Final Rule entitled “Restoring Affirmatively Furthering Fair Housing Definitions and Certifications.” We are heartened to see HUD moving toward restoring a meaningful Affirmatively Furthering Fair Housing (AFFH) rule to better implement the letter and spirit of the Fair Housing Act (“the...

Office of Management and Budget RFI: Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government

From the letter to Acting Director Shalanda Young, Office of Management and Budget We the undersigned civil rights and consumer advocacy organizations are writing in response to the Office of Management and Budget’s May 5, 2021, Request for Information on Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government. We applaud the OMB for seeking...

Testimony: To Help Communities of Color and Spur Economic Recovery, Student Debt Cancellation Must be a Part of the Solution

From the testimony delivered by Julia Barnard at the Department of Education's June 23rd hearing: Good afternoon. My name is Julia Barnard, researcher and student loan team co-lead at the Center for Responsible Lending (CRL), a national advocacy organization focused on fighting predatory lending. I am here to deliver a statement on behalf of the Center for Responsible Lending. Even...

Urging HUD to Extend the Foreclosure Moratorium and Deadline to Request Forbearance for FHA Borrowers

From the letter to Secretary Marcia L. Fudge: On behalf of the clients and communities we represent, the 155 undersigned organizations are writing regarding the FHA foreclosure moratorium and the deadline for FHA borrowers to access COVID-19 forbearance plans, both of which expire on June 30, 2021, pursuant to Mortgagee Letter 2021-05. We urge HUD to extend the foreclosure moratorium...

First Generation: Criteria for a Targeted Down Payment Assistance Program

This proposal for a national Down Payment Assistance (DPA) program was developed by the Center for Responsible Lending and the National Fair Housing Alliance from the perspective of providing the U.S. Congress with a framework for establishing a Targeted Downpayment Assistance Program to close the wealth and homeownership gaps. However, the elements of this proposal can be adapted for use...

Protections for Borrowers Affected by the COVID-19 Emergency Under the Real Estate Settlement Procedures Act (RESPA), Regulation X

The Center for Responsible Lending (CRL) and the National Community Stabilization Trust (NCST) appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s proposed rule on Protections for Borrowers Affected by the COVID-19 Emergency Under the Real Estate Settlement Procedures Act (RESPA), Regulation X. Our organizations strongly support the Bureau’s goals of preventing avoidable foreclosures and maximizing home retention...

Opposition to the National Credit Union Administration’s Proposal which Would Authorize Predatory Lending by Credit Unions

The following two comments oppose the National Credit Union Administration (NCUA or the Board)’s proposal to expand the activities in which credit union service organizations (CUSOs) are permitted to engage. This proposal will authorize predatory lending by credit unions, hampering household security at a time when greater security is badly needed. It will also increase racial discrimination, as families of...

Correcting the Record: The OCC’s “Fake Lender” Rule Expands Harmful, Predatory Lending

The Office of the Comptroller of the Currency’s (OCC) “fake lender” rule is an existential threat to state interest rate limits that protect consumers from predatory lending. Since the American Revolution, states have limited interest rates to stop predatory lending. Forty-five states and the District of Columbia (DC) have interest rate caps on at least some installment loans, depending on...

Potential changes to the FHA COVID-19 modification options to keep more borrowers in their homes

Millions of homeowners across the country are having difficulty affording their monthly mortgage payments because of the COVID-19 pandemic. The most vulnerable group of borrowers is concentrated within the Federal Housing Administration (FHA) program, with over 900,000 borrowers who are more than 90 days delinquent. While the CARES Act provided homeowners with access to a mortgage forbearance and while subsequent...

Hardship for Renters: Too Many Years to Save for Mortgage Down Payment and Closing Costs

Saving for a mortgage down payment is a significant barrier to homeownership that particularly hits communities of color. We calculate how long it would take for a typical renter household to save for a mortgage down payment and closing costs for a median-priced house (“Years to Save”) and further disaggregate these calculations by race/ethnicity, household type, location, and occupation. We...

Comment to the Federal Housing Finance Agency on Request for Input on Climate and Natural Disaster Risk Management at the Regulated Entities

The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Request for Input on Climate and Natural Disaster Risk Management at the Regulated Entities. CRL is a nonprofit, non-partisan research and policy organization dedicated to protecting homeownership and family wealth by working to eliminate abusive...

Comment to the Department of Financial Protection and Innovation on Reining in Abusive Practices in the Bail Bonds Industry

The private bail bonds industry is woefully underregulated. Unlawful consumer credit arrangements and debt–collection practices abound, yet no government body is charged with addressing these aspects of bail bonds contracts. DFPI has the authority and the expertise to provide much-needed regulation in this industry and doing so would align with its mission. For the good of bail bonds consumers too...

Broad Coalition Calls for Congress to Rescind “Fake Lender” Rule that Facilitates Predatory Loan Schemes

The coalition of signatories to the letter consists of 325 groups, including civil rights, community, consumer, faith, housing, labor, legal services, senior rights, small business, student lending, and veterans organizations. The letter states that “[t]he rule replaces the longstanding ‘true lender’ anti-evasion doctrine with a ‘fake lender’ rule that allows lenders charging rates of 179% or higher to evade state...

Poll: Minnesota Student Loan Borrowers During COVID-19 Pandemic

Key points from the poll results include: Download a one-page summary of the results. As a result of the COVID 19 crisis, payments have been paused for federal student loan borrowers nationwide until at least September 2021 Almost one in three 28 Minnesota borrowers are not confident that they will be able to resume payments on their student loans when...

Coalition Letter: Congress Should Extend the Paycheck Protection Program (PPP). The Schedule C Fix Must Be Made Retroactive

Over 60 community development, civil rights, and small business groups are urging swift extension of the Paycheck Protection Program by Congress. The extension should not preclude any necessary SBA rulemaking authority. The letter also flags the continued need to make the recent change for Schedule C filers retroactive.

Suing-to-Intimidate: New Evidence Confirms that Oportun Abuses and Intimidates Families in Court to Collect Small-Dollar Loan Debts in California Courts

“Oportun,” is almost a translation of the Spanish word for “opportunity,” but is a few letters shy of the full word: oportunidad. Unfortunately, Oportun’s practices leave people questioning just how much financial opportunity consumers receive as a result of using these products. “Partner with us today to build a better tomorrow.” “We’re committed to our community.” These messages and other...

Group Comment to the Department of Financial Protection and Innovation on Income Share Agreements (ISAs)

On September 25, 2020, Governor Newsom signed AB 1864 (Chapter 157, Statutes of 2020), establishing the California Consumer Financial Protection Law (“CCFPL”) under Division 24 of the Financial Code. The undersigned consumer advocates are encouraged to see that the Department of Financial Protection and Innovation (“DFPI” or the “Department”) is seeking input from stakeholders in developing regulations to implement the...

Comment on Proposed Rulemaking under the California Consumer Financial Protection Law: Earned Wage Access

This set of comments will focus on earned wage access programs and other newer types of payday advance programs. NCLC and CRL have also joined a broader set of comments submitted by the California Economic Justice Coalition on a broader range of issues and a second set in conjunction with the Student Borrower Protection Center on income share agreements. These...
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