Comment Letter

H.R. 1737 would frustrate efforts to crack down on discriminatory auto lending practices. The bill places unnecessary restrictions on CFPB oversight of auto lending, including interest rate markups that cost consumers tens of billions of dollars and have been found to violate fair lending practices through a differential impact on minority purchasers of automobiles. The restrictions in this bill do not exist for any other financial practice. Download the comment letter above and download a supplemental factsheet on discrimination in auto lending. Homepage photo credit

On July 13 CRL submitted this comment letter detailing its concerns with the state of student loan servicing.

Comment of the Center for Responsible Lending and the National Consumer Law Center (on behalf of its low income clients) on the Proposed Amendments to the Cash Management Rule, 34 C.F.R. Part 668. Also see broad coalition comments to the Department of Education

In this letter (2 pages), 16 consumer, civil rights, and housing groups ask Members of Congress to oppose H.R. 650, The Preserving Access to Manufactured Housing Act 2015. The groups argue that the bill would roll back protections established by the landmark Dodd Frank Wall Street Reform and Consumer Protection Act and hurt low and moderate income families. The groups state H.R. 650 would: Raise the interest-rate trigger for protections under the high-cost mortgage protections of the Home Ownership and Equity Protection act (HOEPA) Raise the points-and-fees trigger for HOEPA protections Exempt...

We write to thank the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) for the proposed guidance addressing bank payday lending, particularly the underwriting requirements and limits on repeat loans. These critical provisions address a central problem with payday lending: lenders’ failure to verify the borrower’s ability to repay the loan, and meet other expenses, without reborrowing, leading to a destructive cycle of repeat loans that trap borrowers in long-term debt. This proposed guidance is urgently needed...

Remarks by Bill Sermons, Research Director from the Center for Responsible Lending, before the Credit Reporting Field Hearing convened by the Consumer Financial Protection Bureau in Detroit, Michigan on July 16, 2012.

CRL and other allied organizations are pleased to submit the following comments on payday lending abuses in response to the Consumer Financial Protection Bureau's request after its January field hearing in Birmingham, Alabama. CRL and the other organizations appreciate the chance to comment on the debt trap inherent to payday lending, and are grateful for the supervisory guidance on payday lending that the Bureau has issued since the Birmingham event. The comment letter analyzes research results to demonstrate the following points: Payday loans are structured to create a long-term debt trap...

The need for mortgage relief continues to grow, but too often companies that promise mortgage assistance relief services (MARS) turn out to be scammers. CRL and its allies recently submitted comments to the Federal Trade Commission, which is considering tighter rules to ensure that people who pay for mortgage assistance actually have a fair chance of receiving help.