Policy & Legislation

Industrial loan companies (ILCs) or industrial banks (IBs) (together, “ ILCs”) typically enjoy the privileges of traditional banks but pose two significant risk factors unique to ILCs: They are not subject to the Federal Reserve’s supervision, which occurs at the consolidated level (i.e., the ILC’s parent company, the ILC, and their affiliates); and They permit the intermingling of commercial and...

The Problem High-cost lenders are ignoring state law and continuing to lend high above the state's legal interest rates, using a practice called Rent-A-Bank. In some cases, these rates are under 36% on very large loans. In others, rates are in the triple-digits, charging consumers up to 200% to finance car repairs, furniture, and even puppies. How Rent-A-Bank Works In...

On May 20, 2020, the Office of the Comptroller of the Currency (OCC) acted alone in issuing a structurally flawed final rule on the Community Reinvestment Act (CRA) that weakens the CRA and will harm low- and moderate-income (LMI) communities and communities of color. Rather than postpone rulemaking to focus on the devastating economic crisis caused by the COVID-19 health...

The Paycheck Protection Program (PPP) is a revenue replacement program designed to sustain small business jobs during the ongoing public health and economic crisis. The effect of the crisis on small businesses has been profound—over half of small businesses said the crisis has had a large negative effect on their businesses and 74% of small businesses said they have had...

The COVID-19 crisis is having profound financial impacts on families across the country and on the economy overall. With businesses shuttered, and over 22 million unemployment claims filed in the first month of the crisis alone, it is hard to overstate the financial instability and hardship the crisis has produced. These impacts will worsen over time, as immediate income shortfalls...

The Small Business Administration Paycheck Protection Program (PPP) has failed to fairly serve businesses owned by people of color, causing spill-over harms throughout communities of color, states, and regions. Businesses owned by people color are a substantial source of income and employment—accounting for more than 8.7 million jobs at total annual payroll of $280 billion, and $1.3 trillion in revenue-yet...

H.R. 748, the Coronavirus Aid, Relief and Economic Security Act (CARES Act)—signed into law on March 27, 2020—offers important benefits for the public health crisis caused by COVID-19. However, the bill fails to provide substantive, comprehensive financial relief for vulnerable families who now face economic challenges, such as unemployment and reduced work hours, as a result of the crisis. It...

Even before the onset of the COVID-19 pandemic, US household debt was on the rise, reaching over $14 trillion. While much of this debt stems from mortgages, a growing amount stems from non-mortgage consumer debt, including student loans, medical debt, credit cards, installment loans, and auto loans. With the number of Americans facing unemployment, lost wages, and depleted savings due...

H.R. 748, the Coronavirus Aid, Relief and Economic Security Act (CARES Act), signed into law on March 27, 2020, provided for a 6-month suspension and interest waiver on federally-owned student loans. It also halted all involuntary collections on these loans. These provisions only apply to Department of Education-held loans, excluding 1.9 million Perkins Loan borrowers, 5.98 million commercially held FFEL...

Housing accounts for almost 20% of our national economy. Disruptions in the housing sector will have a ripple effect across the economy. This crisis lays bare wealth and income inequality, including the racial wealth gap, that worsened in the last crisis and the structural flaws in our economy that produce this inequality. Actions must be taken now to protect financially...