Analysis of OCC Guidelines Establishing Standards for Residential Mortgage Lending Practices
While we are heartened that the OCC has recognized many of the issues raised by state anti-predatory lending efforts in recent years, the OCC's guidance for national banks is no substitute for meaningful and effective legislative efforts at the state and federal level. Further, we are disappointed that the OCC does not identify some practices as clearly predatory and take a stronger stance on enforcing rules that prohibit banks from engaging in predatory lending. The Guidelines demonstrate recognition of some predatory lending issues, but are insufficient to protect homeowners from abusive...
Comments on Regulation E—Overdraft Practices
The Center for Responsible Lending, along with Consumer Action, Consumer Federation of America, Consumers Union, National Association of Consumer Advocates, National Consumer Law Center (on behalf of its low-income clients), and U.S. PIRG provide the following comments regarding the Federal Reserve Board's proposed rule to amend Regulation E pursuant to the Electronic Funds Transfer Act. Summary of recommendations: Revisit the proposal to use the Board's UDAP authority under FTC Act to require institutions to provide a choice about coverage for checks and ACH transactions. Require institutions...