A Policy-Related Reporting Change, Not Increasing Financial Distress, is Driving the Recent Increase in the FHA Serious Delinquency Rate

The 90D+ delinquency (DQ) rate on loans insured by the Federal Housing Administration (FHA), which captures loans that are 90 or more days delinquent but not in foreclosure or bankruptcy, has increased sharply. At 3.57% in September 2025, it has since risen to 5.23% in January 2026, an increase of 1.66 percentage points (pp) in just 4 months. Market commentators...

We Concur: Courts Unanimously Say Payday Loan Apps Subject to the Military Lending Act

The Military Lending Act (MLA) provides protections for active-duty service members and their families, including a 36% interest rate cap. This one-pager examines how payday loan apps, often marketed as Earned Wage Advance, attempt to evade these protections by claiming they are not loans. It also highlights a growing body of court decisions rejecting those claims and recognizing these products...

Recommendations for Implementing a Cost-Effective VA Loss Mitigation Program

The Department of Veterans Affairs (VA) holds 25% of the risk of loss associated with borrower default on VA-guaranteed mortgages. Therefore, VA has an economic interest in directing mortgage servicers to engage in risk management techniques that will reduce the number of defaults on VA-guaranteed loans that transition to disposition (i.e., foreclosure, short sale, or deed-in-lieu of foreclosure) and cause...

Statewide Poverty Action Network and CRL Testify at Washington Legislature Work Session on Buy Now, Pay Later (BNPL)

Nadine Chabrier, CRL Senior Policy Counsel, teamed up with Molly Gallagher, Statewide Poverty Action Network Policy Lead, to talk to Washington state representatives about the importance of examining BNPL policy during the affordability crisis. Watch the full video to see Molly Gallagher's presentation and more.

State-by-State Action on Payday Loan Apps

Payday loan app companies try to evade state credit laws by promoting a legal fiction: they claim that these loans are not loans. As state regulators and attorneys general investigate and challenge industry violations of credit law, these lenders have lobbied state legislatures for exemptions from those laws. This state law chart serves as a shorthand guide to state regulation...

Student Loan Borrower Protections Under Threat Factsheet

In 2025, the Department of Education and Congress reshaped the student loan system through new laws, administrative actions, and proposed rules that could bring further changes. Together, these actions mean higher costs, fewer protections, and more uncertainty for millions of borrowers. Here is what is happening and how it could affect borrowers. Download the full factsheet. CRL Advocacy Priorities Protect...

States Should Protect Consumers from Lenders’ Efforts to Increase the Cost of Already Expensive Consumer Installment Loans

Consumer installment loans offered by nonbank lenders can be an expensive form of credit that keeps borrowers in costly long-term debt. Lenders offer these loans to individuals for their personal or household use. Consumers borrow between $1,000 to $25,000 or more. Many states regulate the costs and other terms of these loans, usually requiring them to be repaid monthly over...

Payday Loan Apps

Payday loan apps offer small, short-term loans that are typically repaid on the consumers’ next payday. These products are sometimes called Earned Wage Advance, Early Wage Access, or EWA but few merit this name. Research by CRL and others has demonstrated using these apps leave many consumers worse off - paying high fees for small loans, increasing their risk of...