Threat that National Banks Could Help Predatory Lenders Charging 135% to 199% Apr to Evade New California Law

A coalition of 61 consumer, civil rights, and community groups sent letters to three federal bank regulators urging them not to allow their banks to help payday lenders evade state interest rate limits. The groups sent separate letters to the Federal Deposit Insurance Corp. (FDIC), which regulates the only banks currently involved in rent-a-bank schemes; the Office of the Comptroller of the Currency, which regulates a national bank that has been in talks with a payday lender; and the Board of Governors of the Federal Reserve System, whose banks so far do not appear to be engaged in rent-a-bank...

Preserving and Strengthening Access to Stable, Affordable, and Equitable Homeownership Opportunities for All American Families

From the letter to the director of the National Economic Council, Lawrence Kudlow: As you consider proposals to restructure our nation’s housing finance system as required by the March 2019 Presidential Memorandum,1 the undersigned civil rights organizations write to express our collective view that any effort to comprehensively reform Government Sponsored Entities (GSEs)—Fannie Mae and Freddie Mac—must recognize the importance of preserving and strengthening access to stable, affordable, and equitable homeownership opportunities for all American families. We view failure to maintain these...

Letter to CFPB on Payday Lending Rule Payment Protections

Consumer watchdog groups urged the U.S. Consumer Financial Protection Bureau (CFPB) to take action immediately to implement the payment provisions in its payday lending rule, whose compliance date is August 19, 2019. These provisions restrict payday and vehicle-title lenders from attempting to withdraw money from borrowers’ bank accounts after two attempts have failed, a practice that significantly harms struggling consumers. The safeguards will help consumers avoid fees for unsuccessful debit attempts that can also put their bank accounts in jeopardy. The CFPB is refusing to take steps to...

Protect Student Loan Borrowers from Discrimination

Student loan borrowers of color disproportionately bear the brunt of America’s student debt crisis, and sadly, the extraordinary levels of delinquency and default across these communities is preventable. The most vulnerable student loan borrowers have a right under federal law to make affordable student loan payments—a powerful protection that should make student loan defaults extremely rare. However, mounting evidence shows that borrowers of color continue to experience extremely high rates of delinquency and default, particularly when compared to their white peers. This evidence suggests...

Response to Senate Democratic Caucus Higher Education Act Reauthorization Principles

The Center for Responsible Lending1 (CRL) appreciates the opportunity to provide comments on principles for the reauthorization of the Higher Education Act (HEA). We commend your dedication to reauthorizing the Higher Education Act with the intention of achieving an affordable, accountable, accessible and equitable and safer higher education system. We hope that you will continue to push for a Higher Education Reauthorization Act that holds true to the spirit of the original HEA, which sought to open the doors of higher education to all. CRL stands firm in the belief that any reauthorization...

Protecting Servicemembers from Abusive Financial Practices

"The undersigned consumer, community, and civil rights organizations write to urge the Consumer Financial Protection Bureau to reverse its recent decision to suspend the supervision of payday, car title, and other lenders for violations of the Military Lending Act (MLA). We also urge the Department of Defense to ensure that the Military Lending Act is vigorously implemented without exemptions or loopholes to protect servicemembers and their families from financial abuse." Download the entire letter.

Broad Coalition Urges Regulators and Banks to Avoid a Return to Toxic Loans that Trap Consumers in Debt

Consumer, civil rights, faith, and community groups are urging the FDIC Chair in this letter to keep in place the agency’s guidance urging banks to not sell these toxic loan products, which are harmful to consumers, banks’ reputation, and its safety and soundness. The coalition’s letter also calls for the FDIC to ensure small dollar installment loans are capped at 36% or less and to prevent bank partnerships that evade state interest rate limits.

Coalition of Community/Consumer groups Comments on Notice of Proposed Rulemaking (PAL II)

We urge NCUA to make no changes to the payday alternative loan (PAL) program that would increase the likelihood that credit union members end up in cycles of high-cost, short-term loans that resemble payday loan debt. Most critically, we strongly oppose permitting more than six application fees in twelve months as proposed for PAL II. We also oppose permitting 28% interest on loans as large as $2,000, dropping the minimum loan size, and proposing a PAL III program that would permit even more expensive or larger loans or weaker underwriting. Finally, we urge NCUA to address abusive overdraft...

Opposition to S. 2155, the So-Called “Economic Growth, Regulatory Relief, and Consumer Protection Act”

The undersigned organizations write to express our opposition to S. 2155, the so-called “Economic Growth, Regulatory Relief, and Consumer Protection Act,” and urge you to oppose this harmful legislation. As you know, S. 2155 passed in the Senate on March 14th. The bill already contains destructive policies that roll back or eliminate essential protections put in place by the Dodd-Frank Wall Street Reform and Consumer Protection (Dodd-Frank) Act after unchecked reckless lending nearly destroyed the US economy. Although this bill seeks to protect smaller lenders while maintaining access to...

Oppose H.J. Resolution 122 and S.J. Resolution 56 and Any Repeal of the Consumer Bureau's Payday Rule

Over 100 North Carolina organizations have joined this state sign-on letter to strongly oppose payday lending. These groups include military and veterans associations, faith organizations, housing and credit counseling agencies, rural, business, civil rights, seniors and labor groups, among many others. They urge our North Carolina congressional delegation to strongly oppose H.J. Resolution 122 and S.J. Resolution 56, fast-track measures that would repeal the Consumer Financial Protection Bureau’s payday rule. These bills not only repeal the rule, they also prevent the consumer bureau from...