Comment on Enterprise Duty to Serve Plan

The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, NAACP, National Coalition for Asian Pacific American Community Development, National Fair Housing Alliance, and National Urban League file this comment in response to Fannie Mae's and Freddie Mac's (the Enterprises) proposed Underserved Markets Plans. Thank you for the opportunity to provide input on the Enterprises’ plans. The...

Comment on 2018-2020 FHFA Affordable Housing Goals

The Center for Responsible Lending and the undersigned consumer, civil rights, and community organizations would like to thank you for the opportunity to submit comments on the Federal Housing Finance Agency’s (FHFA) proposed rule setting the 2018-2020 Affordable Housing Goals for Fannie Mae and Freddie Mac (“Enterprises”). We appreciate FHFA’s efforts to improve strategies to ensure those from lower wealth...

Request for Information on Eliminating Regulatory Barriers to Affordable Housing

Deregulatory measures are not the antidote to the affordable housing crisis in our nation. The government must provide the necessary investments to combat the crisis and ensure that potential regulatory changes enhance equity, not detract from it. HUD and the White House Council must not use the RFI process to undermine important public interest protections, such as civil rights, labor...

Comment: Access to Capital Is One of the Greatest Barriers to Success for Minority Entrepreneurs

NALCAB, the National Association for Latino Community Asset Builders, The National Coalition for Asian Pacific American Community Development (CAPACD), and the Center for Responsible Lending (CRL) write in response to the invitation for public comments regarding changes made to the Community Advantage Pilot Program (CA) noticed in the Federal Register on April 29th, 2022. Access to capital is one of...

Comment to the Federal Housing Finance Agency on Prior Approval for Enterprise Products

CRL urges FHFA to provide for a streamlined approval process for the GSEs to submit new activities that do not rise to the level of a new product. Otherwise, given the proposed rule’s extraordinarily broad definition of a new activity, the GSEs will be stymied from pursuing new endeavors by excessive red tape and overly burdensome documentation requirements. A streamlined...

Consumer Rights Organizations Call on FDIC to Downgrade TAB Bank on its Community Reinvestment Act Exam

From the introduction to the comment: 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), Public Citizen, US PIRG and the Woodstock Institute submit these comments in connection with the Community Reinvestment Act (CRA) examination of Transportation Alliance Bank (dba TAB Bank). TAB...

CFPB Should Protect Consumers From “Junk Fees”

The Center for Responsible Lending (CRL), along with Americans for Financial Reform (AFR), Consumer Federation of America (CFA), the National Community Reinvestment Coalition (NCRC), and National Consumer Law Center (NCLC) (on behalf of its low-income clients) submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to their call for public input on how to save Americans...

CFPB Should Treat 'Buy Now, Pay Later' Products Like Credit Cards and Protect Consumers from Harmful Practices.

In response to the Request for Comments issued by the Consumer Financial Protection Bureau, the Center for Responsible Lending, the Consumer Federation of America, and the National Consumer Law Center (on behalf of its low-income clients) offer joint recommendations for further guidance and monitoring of the growing Buy-Now-Pay-Later market overall, which are specific to the "pay-in-four" model. Our comment covers...

77 Groups Urge the CFPB to Supervise the 'Buy Now, Pay Later' Market

The group letter begins: The undersigned 77 consumer, housing, civil rights, legal services, faith, community, small business, student borrower, and public interest organizations appreciate the opportunity to comment on the CFPB’s inquiry into Buy Now, Pay Later (BNPL) credit products that are proliferating across market areas. We welcome the CFPB’s recent inquiry into Affirm, Afterpay, Klarna, PayPal, and Zip, however...

Advocates Outline a Path Forward for California to Rein in Shadow Student Debt

In a letter to California’s Department of Financial Protection and Innovation (DFPI), the Student Borrower Protection Center, the Center for Responsible Lending, the Consumer Federation of California, Consumer Reports, the Student Debt Crisis Center, the National Consumer Law Center, NextGen Policy, and Young Invincibles commented on proposed rules for education financing products in California. The letter notes that the DFPI’s...