Comment: CRL and Self-Help Support the CDFI Fund’s Adoption of Meaningful Consumer Protections in CDFI Certification Application

The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund strongly support the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. In November 2020, CRL and Self-Help urged the Fund to adopt several critical consumer protections in the Fund’s certification application. We are very pleased to see that the Fund has proposed to adopt many of those protections, including:

• Limiting the ability of CDFIs to lend at interest rates that exceed 36%
• Requiring CDFIs to lend based upon a borrower's demonstrated ability to repay
• Requiring CDFIs to abide by key Qualified Mortgage protections, which prevent lenders from originating the sort of mortgages that helped cause the Great Recession

CRL and Self-Help’s recent comments explain why these protections are necessary and urge the Fund not to weaken them when, inevitably, industry opposes the changes.