Research & Policy

On November 2, 2021, Marisabel Torres, director of California Policy, CRL testified before the House Task Force on Financial Technology. Her written testimony as well as her oral remarks are available for download. Watch the live hearing:

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...

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...

Read the full comment for a: Summary of the current racial disparity in homeownership caused by longstanding and continuing discrimination; Discuss of the challenges and opportunities in redressing these disparities; Suggested steps to maximize the role of the GSEs in this endeavor.

The Center for Responsible Lending, Americans for Financial Reform Education Fund, and the National Community Stabilization Trust support FHFA’s proposed affordable housing goals for the GSEs and would support a higher subgoal for the GSEs buying mortgages for homes in minority tracts where borrower income was not above 100 percent of AMI. Encouraging the GSEs to provide more families with...

The Center for Responsible Lending (CRL), the Consumer Federation of America (CFA), the National Consumer Law Center (NCLC) (on behalf of its low-income clients), and the National Fair Housing Alliance (NFHA) submitted a comment on the Proposed Interagency Guidance on Third-Party Relationships with an emphasis the following points: A handful of FDIC-supervised banks are engaged in high-cost rent-a-bank schemes, which...

The CFPB should rescind the Bureau’s November 2020 EWA Advisory Opinion or to revise its unsound reasoning to prevent evasions of credit laws. The CFPB should also revisit the December 2020 Compliance Assistance Sandbox Approval Order regarding PayActiv for the same reason, and to order PayActiv to cease misusing the order. We also urge the Bureau to eliminate or significantly...

The National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending wrote to the CFPB to express serious concerns about two actions that the CFPB took a year ago under Director Kathy Kraninger finding that certain earned wage access (EWA) products are not “credit” under the Truth in Lending Act. These actions and the...

From the opening paragraph of the letter: On behalf of the undersigned civil rights, consumer protection, and housing policy organizations, we write to urge your continued prioritization of the housing-related provisions in the upcoming reconciliation package. These provisions are a down payment on this Administration's commitment to addressing long-standing inequities in our housing system and addressing the worsening racial wealth...

On September 1, 2021, Tracy Ward, director of the SBA 504 Loan Program at Self-Help Ventures Fund testified before the House Committee on Small Business. Her written testimony as well as her oral remarks are available for download. Watch the live hearing: Ward focused on the following recommendations, which we believe are necessary to correct inequities in the PPP forgiveness...

The Center for Responsible Lending, Self-Help Credit Union, and Self-Help Federal Credit Union submitted this public comment letter to the Department of Housing and Urban Development in support of its proposed rule to recodify its previously promulgated rule titled, “Implementation of the Fair Housing Act’s Discriminatory Effects Standard” (2013 Rule). The comment supports restoring the power of the “disparate impact”...

Even before COVID-19, student loan borrowers struggled under the weight of more than $1.6 trillion in debt. One in four borrowers was in default or serious delinquency, and many worried about their ability to make student loan payments while covering other basic needs. Because of decades of structural inequities and discrimination, student loans have burdened Black and Latino borrowers more...

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...

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...

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:

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.

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...

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...

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...

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...

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...

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...

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...

On April 28, 2021, Lisa Stifler testified in front of the Committee on Banking, Housing, and Urban Affairs during a hearing entitled, "The Reemergence of Rent-a-Bank?" Her written testimony as well as her oral remarks are available for download. Watch Lisa Stifler's opening remarks and the entire hearing:

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...