Research

Banks pitch payday loans as short-term borrowing that allows their customers to deal with a financial emergency, repay the loan, and move on. In fact, CRL's research shows that their triple-digit interest rate loans trap borrowers in a long-term cycle of repeat loans. Read the full report Read the summary Banks continue to claim that their payday products are intended...

CRL and allied organizations maintain that CFPB's proposal addresses two issues critical to the future of safe, sustainable, and affordable access to mortgage credit. First, it considers how to define compensation for the purpose of calculating the points and fees cap contained in the qualified mortgage definition. Second, it proposes a series of exemptions for specialized lending programs and financial...

Dear Chairman Bernanke, Director Cordray, Director Gruenberg, and Comptroller Curry: One year ago, we wrote to urge the federal regulators of our nation's banks to take immediate action to stop banks from making unaffordable, high-cost payday loans. We were encouraged by the FDIC's May letter indicating that it was deeply concerned and was investigating the practice, and we have also...

CRL offers supports the Bureau's consumer protection proposal for mortgage rules and disclosures for high-cost (HOEPA) loans. But it urges CFPB to be vigilant about evasions of HOEPA and to adopt a regulation that is expansive enough to capture all loans structured to evade HOEPA.

In this comment, CRL affirms that limits on loan originator compensation contained in the Dodd-Frank Wall Street Reform and Consumer Protection Act and in Regulation Z are important consumer protections that fundamentally improve the mortgage market, and offers some suggestions for improving standards proposed by CFPB.

Applying safety and soundness standards to bank payday loan products follows longstanding principles and policy of the prudential regulators. Consistently, the prudential regulators, including the OCC, FDIC and the Federal Reserve, have addressed problems with a variety of consumer lending products by citing not only consumer protection concerns, but also safety and soundness concerns, even when those products are very...

Banks that engage in payday lending have been in the media spotlight. Here we give a large sample of recent media coverage, legislative proposals, and public concerns directed at debt-trap lending by banks.

Payday Loans Create a Debt Trap. For California families living paycheck to paycheck, the high price of a payday loan and the fact that it must be paid off in one lump sum two short weeks later virtually ensures that cash-strapped borrowers will be unable to meet their basic expenses and pay off their loan with their next paycheck. Consequently...

A recent CoreLogic report ( The Mortgage Market Impact of Qualified Mortgage Regulation) asserts that 48 percent of the mortgage market would not qualify as a "safe loan" under new Qualified Mortgage (QM) guidelines. CRL's review of this study finds that CoreLogic's model unnecessarily excludes certain categories of loans and makes broad (and possibly unwarranted) assumptions about the expiration of...

This is CRL's comment to the CFPB in response to the Consumer Financial Protection Bureau's Request for Information Regarding Credit Card Market. In this response, CRL argues that the Credit CARD Act of 2009 has made pricing clearer without restricting credit, raising its cost or curbing the ability of card issuers to price for risk. Contrary to curbing risk-based pricing...