Research & Policy

The Center for Responsible Lending and several consumer, faith, community, and civil rights groups wrote to strongly oppose an Office of the Comptroller of the Currency (OCC)’s proposed rule that could unreasonably limit banks’ ability to decide not to serve particular entities, including payday and other predatory lenders. Download the comment letter.

On December 22, 2020, the Center for Responsible Lending (CRL) in partnership with several organizations submitted two letters to the OCC in regard to Oportun's application for a bank charter. CRL takes concern with Oportun's poor underwriting standards that harm the consumers they purport to serve; their intimidating debt collection practices; their new partnership with DolEx Check Cashing stores; and...

On December 22, 2020, the Center for Responsible Lending (CRL) in partnership with several organizations submitted two letters to the OCC in regard to Oportun's application for a bank charter. CRL takes concern with Oportun's poor underwriting standards that harm the consumers they purport to serve; their intimidating debt collection practices; their new partnership with DolEx Check Cashing stores; and...

Civil rights and consumer groups -- Center for Responsible Lending, National Consumer Law Center, East Bay Community Law Center, National Association for Latino Community Asset Builders, and National Coalition for Asian Pacific Americans Community Development – filed an amicus brief in support of the attorneys general of California, Illinois, and New York in their case against a rule from the...

It is a truism that small businesses are a critical engine of economic opportunity and growth. This is especially true for communities of color: businesses owned by people of color account for more than 8.7 million jobs at a total annual payroll of $280 billion, and these businesses generate $1.3 trillion in revenue. It is also a truism that for...

The Center for Responsible Lending and the undersigned consumer, civil rights, community and faithbased organizations oppose the Bureau’s plans to engage in payday loan disclosure testing. We do so in the broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from the harms...

Key points from the poll results include: Forty-five percent of NC student loan borrowers report a decrease in their household income since the onset of COVID-19, with the most severe impact hitting borrowers who earn less than $50,000 per year (55% reporting a decrease). Seventy-three percent of NC student loan borrowers report that their student loans cause them stress. Additionally...

Our comment discusses ECOA’s purpose, the importance of disparate impact theory, issues around artificial intelligence and machine learning models, special purpose credit programs, preemption, and small business lending. Additionally, CRL signed on to a detailed letter from the Americans for Financial Reform (AFR) Language Access Taskforce regarding the challenges in serving limited English proficient consumers.

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...

The COVID-19 crisis has profound financial impacts on families across the country and on the economy overall. With businesses shuttered (including 40% of Black businesses) and record-breaking unemployment claims filed since March 2020, it is hard to overstate the financial instability and hardship this global pandemic has produced. And it will only get worse. The federal government’s response to the...

Download a table of state student loan servicing laws from the report. (Updated September 2022) Today, 44 million Americans are saddled with student loan debt. They currently owe over $1.5 trillion—an amount which has more than doubled over the last decade. The causes of this exploding debt burden are many: increasing tuition, stagnant wages, the shifting role of federal government...

A legacy of racial discrimination in housing, lending, banking, policing, employment, and otherwise, has produced dramatically inequitable outcomes that persist today. Communities of color, often largely segregated due to the history of redlining and other racially exclusionary housing policy, experience higher rates of poverty, lower wages, and higher cost burdens to pay for basic living expenses. Payday loans cause particular...

Through this poll we explore the financial impacts of COVID-19 on Pennsylvanians. The poll was conducted in June 2020 among a national sample of 415 Pennsylvania student loan borrowers in repayment.

Ten years after the Great Recession, the current economic contraction is again hitting Black and Brown communities and lower-wage workers the hardest – many of whom have never recovered. This crisis is worsening long-standing and growing racial and economic inequities at the very moment of national reckoning with the historic need for their redress. Too often, predatory financial services and...

The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund welcome the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. To that end, we urge the Fund to establish lending standards that function as clear, bright-line eligibility requirements for CDFI certification or renewal...

The undersigned consumer, civil rights, and housing organizations welcome the CDFI Fund (Fund)’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. CDFIs are uniquely suited to promote community development and expand financial inclusion. At times, however, we see CDFIs use “financial inclusion” as the central purported justification for permitting irresponsible lending...

In 2008, Ohio voters affirmed capping the cost of payday loans in the state at 28% interest; however, payday and car-title lenders engaged in schemes to evade the voter-mandated cap, trapping consumers in a cycle of debt with APRs of over 500%. In 2018, Ohio lawmakers approved some restrictions on these lending schemes, but even with these 2018 changes, payday...

In the fall of 2017, after more than five years of outreach and research, the Consumer Financial Protection Bureau (CFPB) issued a regulation to address harms to consumers caused by payday loans, vehicle-title loans, and certain other loans with similar features. In July 2020, the CFPB issued a new rule that repeals core aspects of the 2017 rule. Payday and...

Opportunity in America has never been evenly distributed, but the gains made over the last 100 years are at risk if a conservative Justice is added to the Supreme Court. Just like the many social issues already being covered in the wake of President Trump’s Supreme Court nomination, the nine justices who fill the seats of America’s highest court will...

Over the past 50 years, wage stagnation, as well as already high and rising housing, health care, and education costs have dramatically increased debt loads for the average family. Moreover, recovery from the Great Recession has been uneven. Data show that families of color, Americans born after 1970, and households earning less than $60,000 annually are the least likely to...

From the introduction to the comment to the Federal Housing Finance Agency: On behalf of the undersigned consumer, civil rights, and housing organizations, we would like to thank you for the opportunity to comment on the affordable housing goals for Fannie Mae and Freddie Mac (the GSEs). In exchange for government support, the GSEs have an explicit public interest mission...

Ten years after passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, with the country again facing an economic crisis, new polling data from Lake Research Partners, commissioned by the Center for Responsible Lending and Americans for Financial Reform shows that voters across all political parties are broadly and intensely supportive of strong consumer financial protections and of...

Prior to the COVID-19 crisis, court fines and fees, and other monetary sanctions overly burdened young people and adults involved in the criminal legal system with debt from pre-trial through post-release and beyond. A few months into the crisis, we are seeing that Black and Brown communities are disproportionately facing economic challenges. This is reflected in national unemployment data, where...

From the comment to the CDFI Fund on the Small Dollar Loan Program: The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), NAACP, Americans for Financial Reform Education Fund, Consumer Federation of America, and Public Citizen appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan Program (SDLP)...

From the full comment: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB’s) qualified mortgage (QM) proposed rule. Given CFPB’s decision to end the GSE patch, we believe that a price-based approach is an appropriate and effective method to determine QM status. However, additional safeguards are necessary to ensure that the final rule effectively protects...