Comment Letter

The Federal Trade Commission (FTC) Act makes unfair and deceptive acts and practices (UDAP) unlawful and empowers and directs the FTC to prevent such acts and practices through rule-making and enforcement. The Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") provided clear FTC jurisdiction over most auto dealers, particularly when entering into finance transactions with consumers, while freeing the...

FHFA has the mandate and the opportunity to improve mortgage servicing practices. CRL recommends incentives to encourage better service by loan servicers and to promote more timely and effective loss mitigation, free of abusive and unfair practices.

The Center for Responsible Lending, Consumer Federation of America, Consumers for Auto Reliability and Safety, the National Association of Consumer Advocates, the National Consumer Law Center, and on behalf of its low-income clients the National Council of La Raza have filed the following comments to the FTC in regards to the current state of auto lending and the recent motor...

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...

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...

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...

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...