Comment Letter

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...

The Center for Responsible Lending, the National Consumer Law Center, and Consumer Federation of America commend the CFPB for affirming that paycheck advance loans, regardless of their characterization by lenders, are credit products subject to federal disclosure requirements. As written, the proposed interpretive rule by the Consumer Financial Protection Bureau regarding the applicability of the Truth in Lending Act (TILA)...

The consumer, labor, civil rights, legal services and community organizations wrote with strong support of the Consumer Financial Protection Bureau’s proposed interpretive rule on emerging paycheck advance products, sometimes marketed as “earned wage” products.

CRL and Americans for Financial Reform Education Fund (AFREF) support the proposed rule which amends the Fair Credit Reporting Act Regulation V to prohibit creditors and consumer reporting agencies from using medical debt information for credit eligibility determinations or providing medical debt information that a creditor is prohibited from using. The Fair Credit Reporting Act was enacted, in part, to...

These organizations support the CFPB’s conclusion that accounts used to access BNPL credit are credit cards that must comply with credit card rules governing disputes, errors, periodic statements and disclosures. Those protections will enhance the safety of BNPL credit and make it easier for consumers to manage their finances.

The Center for Responsible Lending submitted a comment to the Consumer Financial Protection Bureau on their interpretive rule regarding Buy Now, Pay Later (BNPL) digital user accounts.

From the comment's introduction: Many mortgage lenders are willing to offer cash-out refinances because the Government Sponsored Enterprises (GSEs) Fannie Mae and Freddie Mac, the Federal Housing Administration (FHA), or the Department of Veterans Affairs (VA) bear the credit risk. However, fewer lenders are willing to make home equity loans, especially to borrowers with lower credit scores, given the associated...

CRL submitted a comment on the Proposed Rule by the U.S. Department of Education on Student Debt Relief for the William D. Ford Federal Direct Loan Program (Direct Loans), the Federal Family Education Loan (FFEL) Program, the Federal Perkins Loan (Perkins) Program, and the Health Education Assistance Loan (HEAL) Program. The Proposed Rule is critically important to Black, Latino and...