Policy Analysis Archive


Testimony before House Financial Services Committee regarding on Accelerating Loan Modifications, Improving Foreclosure Prevention, and Enhancing Enforcement, December 2007

Testimony before the Subcommittee on Housing and Community Opportunity regarding Foreclosure Prevention and Intervention: The Importance of Loss Mitigation Strategies in Keeping Families in Their Homes, November 2007

Letter to Governors regarding Early Disclosures for Non-purchase Money Loans, November 2007

Letter by Coalition Opposing H.R. 3915, November 2007

Analysis of H.R. 3915—as passed out of the House Financial Services Committee, November 2007

Comments of the NCLC and NACA Regarding Advance Notice of Proposed Rulemaking Relating to Unfair or Deceptive Acts or Practices, November 2007

Comments regarding the Proposed Illustrations of Consumer Information for Subprime Mortgage Lending, October 2007

Comments to the Board of Governors of the Federal Reserve System regarding the Board's Authority under HOEPA to Prohibit Unfair Acts or Practices in Connection with Mortgage Lending, August 2007

Group Letter to Federal Reserve Board on HOEPA Authority, August 2007

Letter supporting the Homeownership Protection and Enhancement Act (“HOPE Act”) of 2007, July 2007

Comments to the Commonwealth of Massachusetts Office of the Attorney General regarding Mortgage Lenders and Mortgage Brokers, June 28, 2007 PDF 67KB

Letter Supporting Borrower’s Protection Act of 2007, June 25, 2007 PDF 13KB

Coalition Letter to House Financial Services Committee on Predatory Mortgage Lending, May 21, 2007 PDF 26KB

Comments to the Office of the Comptroller of the Currency to Federal Banking Regulators regarding Proposed Statement on Subprime Mortgage Lending, May 2007

Letter to House Financial Services Committee Leaders Supporting Enhanced Lending Duties under FHA, May 2007

Letter to Banking Regulators regarding the Guidance on Nontraditional Mortgage Product Risk, February 2007

Letter to Senate Regarding Inclusion of Hybrid ARMs in Interagency Guidance on Non-Traditional Mortgages, February 2007

Response to MBA Policy Paper on Suitability, February 2007

Letter to the Financial Services Committee regarding the Accessibility of FHA Programs, January 2007


Comments to Federal Bank Regulators on Proposed Illustrations Regarding Non-Traditional Mortgages, November 2006

Testimony by National Consumer Law Center and Consumer Federation of America Regarding Non-Traditional Mortgage Products, September 2006

Comments to the Federal Reserve Board regarding Home Equity Lending Market, August 2006

Letter to the Appropriations Committee re markup of the HUD Appropriations bill, July 2006

Testimony of J. Robert Hunter before the House Committee on Financial Services Subcommittee regarding Title Insurance Cost and Competition, April 2006

Letter commenting on RESPA reform, April 2006

Comments to the federal banking regulators regarding nontraditional mortgages, March 2006

Letter to FRB re ARM Disclosures, January 2006


Letter in Support the “Preservation of Federalism in Banking Act”, July 2005

Letter to Chairman Oxley and Ranking Member Frank regarding predatory lending in the subprime mortgage market, February 2005

Comments to the Massachusetts Division of Banks regarding 209 CMR §§ 32.32, 34, 40: Predatory Home Loan Practices, March 2005

Point by Point Response To Ney-Kanjorski Predatory Lending Bill, April 2005


Federal Regulation of Consumer Credit: The Cause or the Cure for Predatory Lending, March 2004


Letter to Chairman Oxley of House Financial Services Committee: Foreclosures Are Escalating, November 2003

Testimony to the Subcommittee on Housing and Community Opportunity and Subcommittee on Financial Institutions and Consumer Credit on Protecting Homeowners: Preventing Abusive Lending While Preserving Access to Credit, November 2003

Comments on Community Reinvestment Act Regulations, April 2003

Testimony to the Financial Services Committee Subcommittee on Housing and Community Opportunity re HUD’s Proposal to Reform RESPA, February 2003


Comments on Proposed RESPA Rule to Improve Process of Obtaining Mortgages to Reduce Settlement Costs, November 2002

Letter to NCCUSL Commissioners Opposing Uniform Nonjudicial Foreclosure Act, June 2002

Letter to President of NCCUSL, June 30, 2002


Model State Statute: Home Loan Protection Act - A, November 2001

Comments: HUD Opinion Will Cost Homeowners Millions in Kickbacks, October 2001

Testimony to the Senate Committee on Banking, Housing and Urban Affairs regarding the Increase in Predatory Lending and Appropriate Remedial Actions, July 2001

Letter to HUD General Counsel Richard Hauser regarding HUD's Response to Yield Spread Litigation, July 2001

Comments to the Federal Reserve Board regarding Proposed Changes to HOEPA, March 2001

Comments to the FDIC on Predatory Mortgages, January 2001


Testimony re Amendments to 209 CMR §§ 32.32, 42, 40 High Cost Mortgage Loan Provisions in Massachusetts, October 2000

Comments to the Federal Reserve Board on Its Authority to Expand Protections Against Predatory Lending , August 2000

Comments regarding the Advance Notice of Proposed Rulemaking, July 2000

Testimony: The Increase in Predatory Lending and Appropriate Remedial Actions, May 2000

Comments on HUD's Regulation of Freddie Mac and Fannie Mae, May 2000

Comments: NCLC's Proposal for Predatory Mortgage Reform, February 2000


Letter to Chairwoman Roukema on Mortgage Closing Costs and Relief from RESPA's Section 8, November 1998

Testimony on the Rewrite of Truth in Lending Act and Real Estate Settlement Procedures Act, September 1998

Testimony on Banking and Financial Services regarding the proposed The “Financial Institution Regulatory Streamlining Act of 1998", July 1998

Testimony on FHA's Foreclosure Avoidance Program, June 1998

Comments to Senate Special Committee on Aging on predatory lending, April 1998

Testimony regarding S. 1405 The “Financial Regulatory Relief and Economic Efficiency Act of 1997", March 1998


Testimony  regarding the Rewrite of Truth in Lending Act and Real Estate Settlement Procedures Act and Proposed Moratoria on HUD Employee Compensation Rule and Class Action Suits Challenging Lender Paid Mortgage Broker Fees, July 1997

Testimony  regarding H.R. 607 HOMEOWNERS INSURANCE PROTECTION ACT, March 1997


Testimony regarding H.R. 1362 FINANCIAL INSTITUTIONS REGULATORY RELIEF ACT OF 1995, May 1995