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...
The Center for Responsible Lending (CRL) and the Center for Community Self-Help (Self-Help) appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Request for Input on Climate and Natural Disaster Risk Management at the Regulated Entities. CRL is a nonprofit, non-partisan research and policy organization dedicated to protecting homeownership and family wealth by working to eliminate abusive...
The private bail bonds industry is woefully underregulated. Unlawful consumer credit arrangements and debt–collection practices abound, yet no government body is charged with addressing these aspects of bail bonds contracts. DFPI has the authority and the expertise to provide much-needed regulation in this industry and doing so would align with its mission. For the good of bail bonds consumers too...
This set of comments will focus on earned wage access programs and other newer types of payday advance programs. NCLC and CRL have also joined a broader set of comments submitted by the California Economic Justice Coalition on a broader range of issues and a second set in conjunction with the Student Borrower Protection Center on income share agreements. These...
On September 25, 2020, Governor Newsom signed AB 1864 (Chapter 157, Statutes of 2020), establishing the California Consumer Financial Protection Law (“CCFPL”) under Division 24 of the Financial Code. The undersigned consumer advocates are encouraged to see that the Department of Financial Protection and Innovation (“DFPI” or the “Department”) is seeking input from stakeholders in developing regulations to implement the...
Our broad coalition of consumer and business organizations thanks you for the opportunity to comment regarding how the DFPI can best implement AB 1864 (Limón), the California Consumer Financial Protection Law (CCFPL). The CCFPL is an important and significant step forward for California and offers the promise of a bold consumer-facing department that can be at the forefront of consumer...
From the comment: The Center for Responsible Lending (CRL) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) Resolution Planning proposed rule. FHFA seeks comment on a proposal that would require Fannie Mae and Freddie Mac (GSEs) to develop plans to facilitate their rapid and orderly resolution in the event FHFA is appointed receiver pursuant to 12...
The Center for Responsible Lending (CRL)1 appreciates the opportunity to comment on the Affordable Housing Goals Advance Notice of Proposed Rulemaking. In exchange for government support, Fannie Mae and Freddie Mac (GSEs) have an explicit public interest mission. This mission is foundational and part of their charters – the GSEs’ very reason for existing.2 The mission includes promoting access to...
The Center for Responsible Lending and Self-Help filed a joint comment to the Federal Reserve Board on its Advance Notice of Proposed Rulemaking on regulations that implement the Community Reinvestment Act (CRA). Read the full comment.
From the comment letter: NCUA’s proposal, which would permit federal credit unions (FCUs) to keep members’ negative account balances open for longer than the current limit of 45 days, offers no evidence that it will achieve its stated goal -- to provide relief to FCU members. At the same time, the proposal fails to consider the significant risks it poses...