Comment Letter

From the beginning of the comment letter: The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), Americans for Financial Reform Education Fund, and Consumer Federation of America appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan (SDL) Program Application. The comments focus on aspects of the application...

The Center for Responsible Lending, the National Community Stabilization Trust (NCST), the Consumer Federation of America, the National Housing Conference, and the Leadership Conference on Civil and Human Rights, appreciate the opportunity to comment on the proposed rule to amend the Enterprise Regulatory Capital Framework (ERCF) by refining the prescribed leverage buffer amount (PLBA) and the credit risk transfer (CRT)...

The Center for Responsible Lending, Americans for Financial Reform Education Fund, and the National Community Stabilization Trust support FHFA’s proposed affordable housing goals for the GSEs and would support a higher subgoal for the GSEs buying mortgages for homes in minority tracts where borrower income was not above 100 percent of AMI. Encouraging the GSEs to provide more families with...

Read the full comment for a: Summary of the current racial disparity in homeownership caused by longstanding and continuing discrimination; Discuss of the challenges and opportunities in redressing these disparities; Suggested steps to maximize the role of the GSEs in this endeavor.

The Center for Responsible Lending (CRL), the Consumer Federation of America (CFA), the National Consumer Law Center (NCLC) (on behalf of its low-income clients), and the National Fair Housing Alliance (NFHA) submitted a comment on the Proposed Interagency Guidance on Third-Party Relationships with an emphasis the following points: A handful of FDIC-supervised banks are engaged in high-cost rent-a-bank schemes, which...

The Center for Responsible Lending, Self-Help Credit Union, and Self-Help Federal Credit Union submitted this public comment letter to the Department of Housing and Urban Development in support of its proposed rule to recodify its previously promulgated rule titled, “Implementation of the Fair Housing Act’s Discriminatory Effects Standard” (2013 Rule). The comment supports restoring the power of the “disparate impact”...

From the coalition letter to Michael J. Hsu, acting comptroller of the currency, Office of the Comptroller of the Currency: We the undersigned community, consumer, and civil rights organizations write to express serious concerns about Oportun’s application to the Office of the Comptroller of the Currency (OCC) for a national bank charter. Exactly one year ago, Oportun made headlines for...

The undersigned fair housing, affordable housing and civil rights organizations write to you in response to the proposed Interim Final Rule entitled “Restoring Affirmatively Furthering Fair Housing Definitions and Certifications.” We are heartened to see HUD moving toward restoring a meaningful Affirmatively Furthering Fair Housing (AFFH) rule to better implement the letter and spirit of the Fair Housing Act (“the...

The Center for Responsible Lending (CRL) and the National Community Stabilization Trust (NCST) appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s proposed rule on Protections for Borrowers Affected by the COVID-19 Emergency Under the Real Estate Settlement Procedures Act (RESPA), Regulation X. Our organizations strongly support the Bureau’s goals of preventing avoidable foreclosures and maximizing home retention...

The following two comments oppose the National Credit Union Administration (NCUA or the Board)’s proposal to expand the activities in which credit union service organizations (CUSOs) are permitted to engage. This proposal will authorize predatory lending by credit unions, hampering household security at a time when greater security is badly needed. It will also increase racial discrimination, as families of...