Submission to the US Senate Committee on Banking, Housing, and Urban Affairs, April 2017

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...

Opposition to H.R. 1009, the OIRA Insight, Reform, and Accountability Act

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...

Oppose H.R. 998 Searching for and Cutting Regulations that are Unnecessarily Burdensome Act of 2017 (SCRUB Act)

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...

Strong Opposition to H.R. 1004 Regulatory Integrity Act

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’...

Consumer Advocates Urge the Federal Communications Commission to Not Allow Student Loan Companies to Robocall Borrowers

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...

Letter to the Comptroller of the Currency: Innovation Should Not Come at the Expense of Consumer Protection

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...

Strong Opposition to Enabling Lenders to Avoid State Protections and Oversight

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...

Strong Opposition to New Federal Nonbank Lending Charters

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...

Fundamentally Improving Protections for Consumers Victimized by Predatory Debt Collection Practices

The undersigned consumer protection, civil rights, and legal services groups write to express our significant concerns with the outline of proposed regulations on debt collection issued by the Consumer Financial Protection Bureau on July 28, 2016. The proposal represents a missed opportunity to fundamentally improve protections for consumers victimized by predatory debt collection practices. Some of the proposed changes will...