Letters to Congress

Last week, calls were made to eliminate the GSE affordable housing goals as a means to move forward legislation to reform the secondary housing finance market. This misguided attempt is not new, and it would harm creditworthy borrowers who cannot access the mortgage credit they deserve, deny them their chance at the American Dream of homeownership, and weaken our nation’s economy.

This proposal was created by the undersigned consumer and civil rights groups in response to the United States Senate Committee on Banking, Housing, and Urban Affairs’ (Banking Committee) request for proposals to foster economic growth. The proposals revolve around 1) promoting responsible, sustainable homeownership and other responsible lending products for borrowers from low-and moderate income (LMI) households, communities of color, rural communities, and first time home buyers along with rules and policies that incentivize lenders, and, 2) support for the Consumer Financial Protection...

The Center for Responsible Lending (CRL) opposition letter details the many dangerous aspects of the bill.

The OIRA Insight, Reform, and Accountability Act is portrayed as a mere codification of previous Executive Orders, but in fact it further undermines the rulemaking process. It would codify the numerous burdensome requirements contained in the orders– many of which are biased against protecting the public, vague, and in some cases mutually inconsistent — and would have the disastrous effect of making compliance subject to judicial review. In many instances, the legislation also removes flexibility in the Executive Orders with narrower, inflexible language. Particularly concerning, this bill...

H.R. 998 would establish a new bureaucracy empowered to dismantle long-established science-based public health and safety standards and would make it significantly more difficult for Congress and federal agencies to implement essential future protections. Along with previous bills that have passed the House and the President’s Executive Orders instituting a regulatory freeze and requiring the removal of two rules for every one that is finalized, this legislation demonstrates a concerted attack on the process that Congresses have instituted to protect Americans from those risks that they cannot...

H.R. 1004 will significantly undermine federal agencies’ ability to engage and inform the public in a meaningful and transparent way regarding its work on important science-based rulemakings that will greatly benefit the public. As a result, the bill will lead to decreased public awareness and participation in the rulemaking process in direct contradiction of the Administrative Procedure Act and agencies’ authorizing statutes, which specifically provide for broad stakeholder engagement.

Petitioners argue that the Budget Rules are arbitrary and capricious and unsupported by either the language of the statute or the record. This is not the case. The record abundantly supports each feature of the Budget Rules. In fact, the Budget Rules are a textbook balancing act by the Federal Communications Commission of the competing goals of the statute: to allow some unconsented-to automated calls to collect federal debt, while protecting call recipients from invasive and costly calls consistent with the purposes of the Telephone Consumer Protection Act (TCPA).

The Center for Responsible Lending (CRL), The Leadership Conference on Civil and Human Rights, and the NAACP have sent a letter to Comptroller of the Currency Thomas J. Curry urging him not to offer national charters to financial technology firms, which could severely undermine state oversight and state laws that protect consumers and small business owners from abusive financial products and practices: The Center for Responsible Lending, along with the Leadership Conference on Civil and Human rights and the NAACP, appreciate the opportunity to comment on the Office of the Comptroller of the...

Over 250 consumer, civil rights, and community groups wrote this letter to the Office of the Comptroller of the Currency to express strong opposition to the proposed new federal nonbank lending charters that would enable lenders to avoid state interest rate caps, other state protections, and state oversight. State laws often operate as the primary line of defense for consumers and small businesses; thus, the proposal puts them at great risk. The letter focuses on three main points: The OCC must not undermine state rate caps. The OCC must not weaken states' ability to oversee lenders and take...

The 49 consumer, civil rights, small business, and other community organizations signed on to this letter to express strong opposition to new federal nonbank lending charters that would enable chartered entities to avoid state interest rate caps, other state consumer protection laws, and state oversight, putting consumers and small businesses at risk. The Office of the Comptroller of the Currency (OCC) has expressed interest in granting a new type of special purpose "national bank" charter for financial technology ("fintech") firms, including firms that engage in lending and other activities...