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...
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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.
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."
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...
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...
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.
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...
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.
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...
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...
From the beginning of the comment letter: The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), Americans for Financial Reform Education Fund, and Consumer Federation of America appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan (SDL) Program Application. The comments focus on aspects of the application...
For-profit colleges are big businesses, primarily funded by taxpayers. Many deliver poor instructional quality at high cost, causing a high proportion of students to drop out. Even for those students who do graduate, gainful employment in the field that they trained for is frequently elusive. Both non-completers and graduates bear high burdens of debt relative to their post college earnings...
The Center for Responsible Lending, the National Community Stabilization Trust (NCST), the Consumer Federation of America, the National Housing Conference, and the Leadership Conference on Civil and Human Rights, appreciate the opportunity to comment on the proposed rule to amend the Enterprise Regulatory Capital Framework (ERCF) by refining the prescribed leverage buffer amount (PLBA) and the credit risk transfer (CRT)...
The $1.7 trillion student debt crisis impacts over 44 million families nationwide, and the burden of student loans falls particularly heavily on Black students because of historical and ongoing systemic racism. While Black families themselves typically have less wealth to draw upon to pay for college due to the racial wealth gap, Historically Black Colleges and Universities (HBCUs) have also...
The $1.7 trillion student debt crisis impacts over 44 million families nationwide, and the burden of student loans falls particularly heavily on Black students because of historical and ongoing systemic racism. While Black families themselves typically have less wealth to draw upon to pay for college due to the racial wealth gap, Historically Black Colleges and Universities (HBCUs) have also...
As Adam Harris writes in his 2021 book, The State Must Provide: Why America’s Colleges Have Always Been Unequal—And How to Set Them Right: “America’s colleges and universities have a dirty open secret: they have never given Black people an equal chance to succeed.” Despite long-standing systemic challenges and the small average size of Historically Black Colleges and Universities (HBCUs)...
The $1.7 trillion student debt crisis impacts over 44 million families nationwide, and the burden of student loans falls particularly heavily on Black students because of historical and ongoing systemic racism. While Black families themselves typically have less wealth to draw upon to pay for college due to the racial wealth gap, Historically Black Colleges and Universities (HBCUs) have also...
Nationally, HBCUs (Historically Black Colleges and Universities) generate more than 130,000 jobs and almost $15 billion annually in total economic impact for their local and regional economies. But HBCUs have been underfunded throughout their histories. Couple that reality with the fact that student debt is a $1.7 trillion crisis in America, with one in four borrowers in default or serious...
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...
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...
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 (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...