Letters to Congress

This CRL letter to Congress expresses support for the Federal Housing Finance Agency (FHFA) updates to its mortgage pricing framework, including FHFA’s assessment on lenders of fees known as Loan Level Pricing Adjustments (LLPAs). The letter also urges Congress to reject H.R. 3564, the so-called Middle-Class Borrower Protection Act, a bill that would rescind FHFA’s recent updates.

The undersigned organizations wrote in strong support of the Bureau’s proposed rule applying Regulation Z to Residential Property Assessed Clean Energy (PACE) loans. In the proposed rule, the Bureau correctly recognizes that PACE financing fundamentally acts as mortgage credit, yet is provided by underregulated or unsupervised entities that often exploit the lien priority granted to tax assessments. As a result, residential PACE financing should be subject to the same regulations that apply to first-lien mortgages. The rule, if enacted, will significantly limit the well-documented abuses that...

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...

The 261 organizations representing millions of students, workers, people of color, veterans, people with disabilities, consumers, and people of faith write in strong opposition to bicameral efforts to use the Congressional Review Act (CRA) to overturn President Biden's actions to pause student loan payments and provide student debt relief for low-income and working-class Americans continuing to recover from the deadly COVID-19 pandemic and its devastating economic fallout.

From the introduction to the letter: On behalf of the undersigned national, state, and local organizations, we urge you to oppose the dangerous package of bills titled the “CFPB Transparency and Accountability Reform Act” that threaten the Consumer Financial Protection Bureau’s (CFPB) funding, organizational structure, and its ability to monitor the marketplace by impeding their rulemaking functions. This package would irreparably harm the CFPB’s effectiveness and ultimately consumers.

National CAPACD, NALCAB, and the Center for Responsible Lending submitted this letter to support the Consumer Financial Protection Bureau’s (CFPB) final Section 1071 regulation which will improve relationship banking by creating a robust and comprehensive data collection regime that helps ensure that small business lending is fair and accessible to entrepreneurs from all communities in the United States.

The following organizations signed on to a letter to Michael Hsu, Acting Comptroller of the Office of the Comptroller of the Currency, urging him to act and ensure that OCC-supervised banks make necessary reforms to their inequitable overdraft programs. Accountable.US Americans for Financial Reform Education Fund California Reinvestment Coalition Center for Responsible Lending Consumer Action Consumer Federation of America Consumer Reports The Leadership Conference on Civil and Human Rights NAACP National Consumer Law Center (on behalf of its low-income clients) Revolving Door Project UnidosUS...

From the letter to the U.S. Department of Veterans Affairs (VA): The dramatic increase in interest rates since the turn of the year has significantly reduced the effectiveness of VA’s current loan modification program. As a result, an additional loss mitigation option is needed to help veterans who cannot afford to resume their originally scheduled mortgage payments and are in need of payment relief. The refund program gives VA the latitude to adjust the terms of the mortgage without increasing the note rate to the prevailing mortgage rate, which will allow the program to provide the payment...

In this letter, several financial services industry and consumer groups expressed support for legislation, introduced in the U.S. Senate, to close the industrial loan company (ILC) charter loophole, the “Close the Shadow Banking Loophole Act."

The Center for Responsible Lending (CRL), American Business Immigrant Coalition (ABIC), and more than 20 consumer, civil rights and advocacy groups and lenders, recently submitted a letter urging the U.S. Treasury Department and U.S. Small Business Administration (SBA) to reverse the Good Faith Error Rule that has prevented more than 300,000 small business owners from obtaining forgiveness of Paycheck Protection Program (PPP) loans. Read the full letter.