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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 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...

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 and the deadline to access forbearance plans to August 31, 2021, for forward mortgages, and to extend this deadline to December 31, 2021, for Home Equity Conversion Mortgages (HECMs, or reverse mortgages).

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 by state and local governments as well as other entities that wish to establish a program that will advance equitable outcomes. According to the 2019 American Community Survey, homeownership among Black...

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. However, we believe the proposed rule as drafted will not achieve the stated goals. The Bureau proposes a pre-foreclosure review period through the...

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 color are disproportionately targeted with these harmful loans. Detailed comment from The Center for Responsible Lending (CRL), Self-Help Federal Credit Union, Self-Help Credit Union, and...

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 the size. These laws are extremely popular. In recent years, Arizona, Montana, South Dakota, Colorado, and Nebraska have passed ballot initiatives, with overwhelming support, establishing or reaffirming rate...

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 FHA policy actions have extended these periods, forbearance is an inherently temporary solution. Ultimately, what will determine whether these homeowners are able to stay in their...

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 also discuss the impact of student loan borrowing on wealth and liquid savings for young households that have attained at least a bachelor’s degree and the likely impact on Years to Save of repaying...

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 financial practices. CRL is an affiliate of Self-Help, one of the nation’s largest nonprofit community development financial institutions. For over 40 years, Self-Help has...

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 often fleeced by unlawful financial products during a particularly stressful moment in their lives, we urge DFPI to recognize and use its authority under the CCFPL, the DCLA, and Cal. Fin. Code...

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 and voter-approved interest rate caps merely by putting a bank’s name on the paperwork – just as payday lenders were doing in the early 2000s.”

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 they need to. Three quarters of MN student loan borrowers report that their student loans cause them stress Additionally, more than half of borrowers 59 report they would have trouble paying for an unexpected expense or are already falling...

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.

“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 similar ones, placed prominently throughout the Oportun website, could lead a consumer in the community to believe that this lender had their best interests in mind. Oportun’s designation as a Community...

On March 16, 2021, Nikitra Bailey testified in front of the Committee on Banking, Housing, and Urban Affairs during a hearing entitled, "Home = Life: The State of Housing in America." Her written testimony as well as her oral remarks are available for download. Watch Nikitra Bailey's opening remarks and the entire hearing:

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 CCFPL. We write this comment in response to the following questions regarding registration requirements that the DFPI posed in 3(a)-(b): For what industries should the DFPI...

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 comments will focus in particular on these questions that DFPI poses: For what industries should DFPI first establish registration requirements under Financial Code section 90009(a)? What are the consumer protection risks posed by those...

From the comment: The Center for Responsible Lending (CRL) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Resolution Planning proposed rule. FHFA seeks comment on a proposal that would require Fannie Mae and Freddie Mac (GSEs) to develop plans to facilitate their rapid and orderly resolution in the event FHFA is appointed receiver pursuant to 12 U.S.C. 4617. Such a resolution plan, also known as a living will, is to ensure that there is a contingency plan for how a large financial institution will sell off assets or be liquidated without causing turmoil...

Our broad coalition of consumer and business organizations thanks you for the opportunity to comment regarding how the DFPI can best implement AB 1864 (Limón), the California Consumer Financial Protection Law (CCFPL). The CCFPL is an important and significant step forward for California and offers the promise of a bold consumer-facing department that can be at the forefront of consumer protection. We look forward to partnering with you and your team to help make that promise a reality. We must first acknowledge that the on-going COVID-19 pandemic has exacerbated disparities for low and...

In the letter from 138 undersigned consumer, civil rights, community, housing, labor, small business, and other public interest groups: Commissioner Chopra is exactly the type of leader we need to serve as the next CFPB director. His commitment to consumer protection, effectiveness at using the tools of government to serve the public interest, and willingness to challenge powerful corporate interests when necessary are exactly what the Bureau needs to fulfill its crucial consumer protection mission. He is dedicated to ensuring a fair and equitable financial marketplace for all consumers and...

From the amicus brief: Unpaid court debt balloons over time as fines and the costs of collection accrue; low-income people risk wage garnishment, asset forfeiture, loss of credit, and even incarceration as collateral consequences of their continued entanglement with the criminal justice system. These burdens fall most heavily on people of color, who are arrested and placed on probation at disproportionate rates compared to white people.

The Center for Responsible Lending (CRL)1 appreciates the opportunity to comment on the Affordable Housing Goals Advance Notice of Proposed Rulemaking. In exchange for government support, Fannie Mae and Freddie Mac (GSEs) have an explicit public interest mission. This mission is foundational and part of their charters – the GSEs’ very reason for existing.2 The mission includes promoting access to mortgage credit to underserved borrowers, including Black and brown families, serving a countercyclical role in the mortgage market, and FHFA’s duty to reasonably support the safety and soundness of...
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