Letters to Congress

The National Consumer Law Center, on behalf of its low-income clients, and the Center for Responsible Lending write with recommendations on how FHA should shape its post-COVID loss mitigation waterfall. As the market turns from a response to COVID-19 to identifying permanent policies informed by lessons learned from the pandemic, FHA has an opportunity to strengthen the options it makes available to homeowners facing hardship. FHA has shown leadership in developing innovative foreclosure alternatives that provide relief in any market condition. We believe FHA should build its long-term loss...

This legislation purports to provide a safe harbor for financial innovation, but too often, “innovation” is synonymous with a lack of meaningful safeguards for consumer financial products. Creating these regulatory “sandboxes” for companies would force agencies to shirk their statutory duties to enforce the law and protect consumers and instead prioritize allowing risky and unproven products into the marketplace before they have been fully evaluated to ensure that they comply with the law and are safe for consumers to use.

The 193 labor, civil rights, consumer, legal services and community groups and academics joined in this letter to express opposition to the draft Earned Wage Access Consumer Act. In the guise of offering protections, the bill obscures its true effect: to exempt fintech cash advances from the Truth in Lending Act, to endorse a form of loan that makes workers pay to be paid, and to facilitate new evasions by payday lenders. It is especially inappropriate to authorize a new class of fintech cash advances with costs imposed on lowwage workers, disproportionately impacting communities of color and...

The Center for Responsible Lending, Housing Policy Council, Mortgage Bankers Association, and National Consumer Law Center (on behalf of its low-income clients) wrote to the Department of Veteran Affairs (VA) to recommend that the VA pursue payment reduction targeting rather than interest rate targeting as part of their upcoming VA Servicing Purchase (VASP) loss mitigation option.

The Center for Responsible Lending, Leadership Conference on Civil and Human Rights, NAACP, National Association of Latino Community Asset Builders (NALCAB), National CAPACD, National Urban League, and UNIDOS US joined in a letter to support "that CDFI certification is truly reserved for mission-driven, community development organizations."

The undersigned organizations, which together represent a broad cross-section of regulated banks, credit unions, and consumer protection organizations, wrote a letter in thanks for introducing the Close the Shadow Banking Loophole Act, and to express their support for this critical legislation which would close the industrial loan company (ILC) loophole in current law. Americans for Financial Reform Bank Policy Institute Center for Responsible Lending Consumer Federation of America Credit Union National Association Independent Community Bankers of America Mid-Size Bank Coalition of America...

In response to the questions posed in the VA’s October 17, 2022 Advance Notice of Proposed Rulemaking, the National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending urge VA to expand the opportunities available to help veteran borrowers avoid foreclosure. The mortgage relief options available for veteran borrowers should not be less favorable than the options available to other borrowers and should provide relief in all market conditions. We appreciate the VA’s engagement with stakeholders and look forward to working with you to find solutions...

In a letter to the author of the Earned Wage Access Consumer Protection Act, advocates warn: "In the guise of offering protections, the bill obscures its true effect: to exempt fintech cash advances from the Truth in Lending Act, to endorse a form of loan that makes workers pay to be paid, and to facilitate new evasions by payday lenders." The bill, currently a discussion draft, was considered as part of a House Financial Services Subcommittee hearing "Modernizing Financial Services Through Innovation and Competition," held on October 25, 2023— a hearing that the Center for Responsible Lending...

In a letter to the House of Representatives' Financial Services Committee, consumer advocates warn that the Financial Services Innovation Act of 2023 would facilitate evasion of existing consumer protection laws and regulations. Citing the foreclosure crisis around 2008 and other examples, the letter states: "Blind endorsement of 'innovations' leads to consumer harms." The bill, currently a discussion draft, was considered as part of a House Financial Services Subcommittee hearing "Modernizing Financial Services Through Innovation and Competition," held on October 25, 2023— a hearing that the...

From the letter: We strongly believe many of the reforms being considered today will harm consumers and the financial markets. These misguided approaches will place every American taxpayer at risk by increasing the likelihood that our nation’s economy may suffer yet another financial crisis. There are two proposals that are especially concerning. The first increases the asset thresholds at which financial institutions become subject to regulatory oversight. There are more than 4,000 banks in the United States, and this legislative draft would exempt all but 50 from having to comply with...