Comment Letter

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...

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...

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...

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...

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

CRL and consumer coalition express concerns about credit card issuer potential violations of the the Credit CARD Act of 2009. Problems related to penalty rate disclosures, variable rates, payment allocation and pick-a-rate are cited.

CRL and other consumer groups provide comment on the Office of Personnel Management's proposed rule regarding garnishment of federal benefits.

CRL and other consumer groups provide comment on the Federal Reserve's opt-in rule and the proposed changes to Regulation DD.