Research & Policy

The Center for Responsible Lending and Self-Help filed a joint comment to the Federal Reserve Board on its Advance Notice of Proposed Rulemaking on regulations that implement the Community Reinvestment Act (CRA). Read the full comment.

100 organizations supporting African American, Latino and immigrant-owned businesses across the country, joined in this letter to request that changes be immediately made to the Paycheck Protection Program (PPP) to increase meaningful access for sole proprietors, independent contractors, and self-employed individuals. While the Economic Aid Act addressed many of the impediments to access for business owners of color, barriers remain...

Over 800,000 self-employed people were behind on their student debt before the pandemic and may be ineligible or have the perception that they are ineligible for the relief they need to survive in a faltering economy. Because of structural inequities including racial wealth disparities, ongoing discrimination in the labor market, and inadequate funding for colleges that well serve higher numbers...

The Center for Responsible Lending applauds Majority Leader Chuck Schumer, Senator Elizabeth Warren; Representatives Pressley, Adams, Bowman, Jones, Omar, and Torres; and Chairwoman Waters for their bicameral resolution urging President Biden to take executive action to cancel up to $50,000 in federal student loan debt using legal authorities already granted by Congress. Cancelling student debt will provide both immediate financial...

Today the Center for Responsible Lending (CRL) filed this brief in the Supreme Court in support of Thelma McCoy's petition to have the court take up undue hardship discharge for student debt in bankruptcy. Currently and for some time, different courts of appeal have split in how they interpret what is "undue hardship," with some courts taking a holistic "totality...

328 undersigned community, civil rights, climate, health, consumer, labor, and student advocacy organizations wrote to urge President-Elect Biden and Vice President-Elect Harris to boost the economy, tackle racial disparities, and provide much-needed stimulus to help all Americans weather the pandemic and the associated recession by using executive authority to cancel federal student debt on day one of the new administration.

CRL urges FHFA to provide for a streamlined approval process for the GSEs to submit new activities that do not rise to the level of a new product. Otherwise, given the proposed rule’s extraordinarily broad definition of a new activity, the GSEs will be stymied from pursuing new endeavors by excessive red tape and overly burdensome documentation requirements. A streamlined...

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...

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...

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...

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 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...

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...

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...