Comment Letter

The Center for Responsible Lending and several consumer, faith, community, and civil rights groups wrote to strongly oppose an Office of the Comptroller of the Currency (OCC)’s proposed rule that could unreasonably limit banks’ ability to decide not to serve particular entities, including payday and other predatory lenders. Download the comment letter.

On December 22, 2020, the Center for Responsible Lending (CRL) in partnership with several organizations submitted two letters to the OCC in regard to Oportun's application for a bank charter. CRL takes concern with Oportun's poor underwriting standards that harm the consumers they purport to serve; their intimidating debt collection practices; their new partnership with DolEx Check Cashing stores; and...

The Center for Responsible Lending and the undersigned consumer, civil rights, community and faithbased organizations oppose the Bureau’s plans to engage in payday loan disclosure testing. We do so in the broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from the harms...

Our comment discusses ECOA’s purpose, the importance of disparate impact theory, issues around artificial intelligence and machine learning models, special purpose credit programs, preemption, and small business lending. Additionally, CRL signed on to a detailed letter from the Americans for Financial Reform (AFR) Language Access Taskforce regarding the challenges in serving limited English proficient consumers.

The Center for Responsible Lending, Self-Help Credit Union, Self-Help Federal Credit Union, and Self-Help Ventures Fund welcome the CDFI Fund’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. To that end, we urge the Fund to establish lending standards that function as clear, bright-line eligibility requirements for CDFI certification or renewal...

The undersigned consumer, civil rights, and housing organizations welcome the CDFI Fund (Fund)’s efforts to more vigorously ensure that the primary mission of any CDFI is to promote community development. CDFIs are uniquely suited to promote community development and expand financial inclusion. At times, however, we see CDFIs use “financial inclusion” as the central purported justification for permitting irresponsible lending...

From the introduction to the comment to the Federal Housing Finance Agency: On behalf of the undersigned consumer, civil rights, and housing organizations, we would like to thank you for the opportunity to comment on the affordable housing goals for Fannie Mae and Freddie Mac (the GSEs). In exchange for government support, the GSEs have an explicit public interest mission...

From the comment to the CDFI Fund on the Small Dollar Loan Program: The Center for Responsible Lending (CRL), National Consumer Law Center (on behalf of its low income clients) (NCLC), NAACP, Americans for Financial Reform Education Fund, Consumer Federation of America, and Public Citizen appreciate the opportunity to comment on the CDFI Fund (Fund) Small Dollar Loan Program (SDLP)...

From the full comment: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB’s) qualified mortgage (QM) proposed rule. Given CFPB’s decision to end the GSE patch, we believe that a price-based approach is an appropriate and effective method to determine QM status. However, additional safeguards are necessary to ensure that the final rule effectively protects...

From the comment to the Office of the Comptroller of the Currency, Notice of Proposed Rulemaking, "National Banks and Federal Savings Associations as Lenders": We, the consumer and civil rights groups named above, write to strongly oppose the Office of the Comptroller of the Currency’s (OCC) proposed rule preempting the authority of states and courts to look beyond contrivances to...