Comment Letter

The California Department of Financial Protection and Innovation (DFPI) should restore cost limits for earned wage advances and other fintech cash advances under proposed regulations rather than allow a temporary registration regime with no cost limits for up to four years, the Center for Responsible Lending, Consumer Federation of California, National Consumer Law Center, and Office of Kat Taylor said...

The NAACP Legal Defense and Educational Fund, Inc. (LDF) and the Center for Responsible Lending (CRL) submitted a comment in response to the federal financial regulators’ proposed rulemaking on Quality Control Standards for Automated Valuation Study after study has found ongoing, significant undervaluation of homes in communities of color and owned by people of color. Due to decades of past...

CRL submitted a comment on the Federal Housing Finance Agency’s Single Family Pricing Framework arguing that the FHFA should take three steps: Revisit and revise the Enterprise Regulatory Capital Framework, which currently imposes excessive capital requirements on the GSEs; Continue the forward momentum of its recent elimination of LLPA’s for first-time homebuyers and certain affordable housing products by expanding its...

With nearly 45 million Americans owing 1.7 trillion dollars in student loan debt, the Department’s intent to establish a negotiated rulemaking committee to examine proposals under the waiver, modification, and compromise authority is critical to increasing fairness and affordability for those who must accrue debt to pursue higher education. The sheer scale of the student loan debt crisis in America—and...

The Consumer Financial Protection Bureau (CFPB) issued a Policy Statement on Abusive Acts and Practices and invited comments from the public. The Center for Responsible Lending applauds the CFPB for its efforts to further clarify abusive acts and practices. The Center further offers insights into how the statement may be strengthened to clarify the ways these acts take unreasonable advantage...

The undersigned organizations commend the Department of Financial Protection and Innovation (DFPI) for moving to regulate abusive fintech lenders, including earned wage advance providers. We are very pleased to support the proposed rules and encourage the DFPI to vigorously enforce them to ensure that California’s most vulnerable consumers are not harmed. Signatories California Employment Lawyers Association (CELA) CA Labor Federation...

The Center for Responsible Lending (CRL) and the National Consumer Law Center (NCLC) expressed support for the Department of Financial Protection and Innovation’s (DFPI) proposal to clarify that fintech cash advances are covered by the California Financing Law (CFL), including its fee and interest rate limits. The proposal requires that lenders be licensed under the CFL, with a temporary licensing...

CRL and more than 50 organizations committed to gender justice submitted a comment in support of strengthening the Department of Housing and Urban Development (HUD) Proposed Rule on Affirmatively Furthering Fair Housing, which was published in the Federal Register on February 9, 2023 (HUD Docket No. FR 6250-P-01) (Proposed Rule).

In response to a Federal Trade Commission (FTC) notice that it intends to issue regulation, CRL joined a coalition of consumer groups in calling for FTC action to rein-in junk fees. Among other topics, this comment letter highlights a CRL report on installment loan companies that would tack on credit insurance and “automobile club memberships” – charges that meet multiple...

Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low- income clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submitted comments for the Community Reinvestment Act (CRA) examination of First Electronic Bank. First Electronic Bank helps at least two nonbank lenders...