Comment Letter

CRL supports the principles laid out in the OCC's proposed guidance on overdraft and bank payday loans, but hopes the OCC will dramatically strengthen its guidance to address existing problems and to avoid inadverdently entrenching abuses. Among our recommendations, CRL urges the OCC to act quickly and decisively to stop payday lending before it becomes pervasive among banks. CRL also urges the agency to stop its banks from posting transactions in order from highest to lowest to increase overdraft fees.

The mortgage market of the future can drive economic growth without shutting out responsible home buyers. Here is an overview of CRL's recommendations to regulators: The Agencies should delay finalizing the QRM rule until after the final QM rule has beenissued. The QRM final rule should be harmonized with the QM final rule to facilitate compliance. QRM loans should meet all QM requirements. Just as the QM requirements will not, and should not, include down-payment or LTV, neither should the QRM requirements. The point is not that down-payments should not be required, but rather that they...

In its first formal comment to the CFPB, the Center for Responsible Lending supports new Dodd-Frank mortgage reforms and urges the CFPB to ensure that lenders have appropriate consequences if they fail to abide by the rules.

CRL joins several groups in opposing proposed rules that would continue the OCC's broad preemption of state laws governing mortgages, credit cards, bank accounts and other banking products.

SUMMARY We commend NCUA for its efforts to encourage federal credit unions (FCUs) to offer responsible small loan products. However, we encourage NCUA to think of this program in the context of two realities: 1) short-term loan products, whether they are called "payday loans" or are offered through a credit union, are likely to trap already vulnerable customers in costly debt; and 2) consumers with the ability to repay responsible loans can be served by existing affordable small loan products, and NCUA should actively encourage increased availability of these products.We recommend that NCUA...

In this letter to federal regulators, CRL and other national civil rights, labor and consumer organizations share their views on the regulation of securitizers of residential mortgage loans - specifically "qualified residential mortgages" or QRMs. The two points made by the letter: 1. Securitized loans should meet basic servicing standards to prevent unnecessary foreclosures 2. QRM standards should not include downpayment requirements that penalize responsible, creditworthy borrowers who lack the wealth necessary for a large down payment. Signers to this comment letter were the following: AFL...

The National Consumer Law Center ("NCLC") respectfully submits the following comments on behalf of its low income clients, as well as Americans for Financial Reform, California Reinvestment Coalition, the Center for Responsible Lending, Consumer Action, Consumers Union, National Association of Consumer Advocates, National Community Reinvestment Coalition, National Fair Housing Alliance and the Neighborhood Economic Development Advocacy Project, regarding the Federal Reserve Board's proposals to revise numerous regulations under the Truth in Lending Act ("TILA") governing home-secured lending...

Download the joint letter >> CRL and a cross-section of civil rights, labor, consumer, housing, community, business, and sustainable and responsible investor groups sent a joint letter to the FDIC expressing support for bringing attention to abusive overdraft practices. The groups support the agency's common-sense recommendations for actions banks should take to treat their customers more fairly while offering recommendations for how the FDIC could further address its banks' deceptive practices. Specifically, the groups support the FDIC for recognizing that charging a customer more than six...

CRL and other consumer advocates filed a comment letter with the FDIC supporting most aspects of the agency's proposed guidance on overdraft. The groups also made recommendations on how the agency could go even further in protecting consumers from excessive overdraft fees. Here is the summary of key recommendations from CRL, Consumer Federation of America, National Consumer Law Center, Consumer Action, Consumers Union, National Association of Consumer Advocates and U.S. PIRG. KEY RECOMMENDATIONS: End excessive overdraft fees at FDIC-supervised banks: Require that any account holder who chooses...

CRL's comments to the FHA on ensuring access to credit for low-wealth and minority borrowers as the agency considers risk management initiatives.