Comment Letter

The purpose of this letter is to complement the National Fair Housing Alliance’s comment letter that CRL is a signatory on by focusing on the procedural deficiencies of the cost analysis section of the Notice of Proposed Rulemaking. Specifically, the comment letter highlights that none of the requisite requirements under the Regulatory Flexibility Act, Executive Order 12866, or § 1022(b)(2)...

The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, the League of United Latin American Citizens (LULAC), Legal Defense Fund, and National CAPACD - National Coalition for Asian Pacific American Community Development submitted a comment letter yesterday to the Consumer Financial Protection Bureau that opposes the CFPB’s Notice of Proposed Rulemaking (NPRM) that would delay and...

The Center for Responsible Lending agrees with the Federal Housing Finance Agency on the importance of acting intentionally and swiftly to positively address this nation’s housing challenges but believe that the proposed rule will not have the desired effect. Specifically: by reducing the low-income purchase goal by 4 percentage points (25% to 21%) for the next three years, nearly cutting...

CRL's comment argues against the proposed rule to limit the Bureau’s supervisory jurisdiction over non-depository institutions by interpreting the phrase “risk to consumers” in the Consumer Financial Protection Act to mean “a high likelihood of significant harm.” In the comment, CRL argues that the Bureau’s proposed interpretation conflicts with the plain meaning of the statute’s words, the statutory context provided...

The Center for Responsible Lending writes this comment to emphasize how the proposed rule’s vague and ambiguous standards would undermine program integrity, create a dangerous precedent for future administrations, and harm borrowers and the communities they serve.

CRL responded to the New York Department of Financial Services Request for Information Regarding Buy Now Pay Later, which requested comments from industry and interested parties on the “Buy-Now-Pay-Later Act" (L.2025, c. 58, Part Y, New York Banking Law Article 14-B). This law represents an essential step towards better protecting New York consumers from financial harm. Specifically, the Act provides...

In this comment, CRL applauds the Department of Housing and Urban Development for taking a critical first step in better understanding buy-now, pay-later financing effects by soliciting information from the general public and all concerned stakeholders. For the reasons discussed in this response, CRL believes that this important step should be followed, however, by focused research into the relationship between...

The U.S. Department of Education’s commitment to reforming Title IV programs presents a historic opportunity to reshape the federal student aid system into one that is more equitable, efficient, and effective. CRL stands ready to support this process and urges the Department to center the needs of students—especially those that are first generational and underrepresented—in all forthcoming regulatory proposals.

On behalf of the Center for Responsible Lending, thank you for the opportunity to comment on the notice of proposed rulemaking (Proposed Rule) by the U.S. Department of Education on Student Debt Relief Based on Hardship for the William D. Ford Federal Direct Loan Program (Direct Loans), the Federal Family Education Loan (FFEL) Program, the Federal Perkins Loan (Perkins) Program...

The National Consumer Law Center, the Center for Responsible Lending and the Student Borrower Protection Center submitted to the Office of the Comptroller of the Currency, Federal Reserve System, and Federal Deposit Insurance Corp. on the Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses. The comments focus on bank-fintech partnerships in the...