NCLC submitted comments in response to the Treasury Department’s request for information on developing a national strategy for financial inclusion. Our comments begin by addressing some of the risks associated with expanding the use of alternative data in credit reporting and argue that “alternative” data is best left outside of the main credit reporting file.…
Comments on FTC's Proposed Rule on Junk Fees, Specifically on Junk Fees that Affect Justice-Involved People
NCLC, the Prison Policy Initiative (PPI), and advocate Stephen Raher submitted comments in response to the Federal Trade Commission’s (FTC) Proposed Rule on junk fees. These comments address the Proposed Rule as it would apply to junk fees that affect justice-involved people. Unfortunately, these fees are very common, and they cause particular harm to consumers…
Comments on Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications
NCLC urges the CFPB to finalize a rule that would establish supervisory authority over larger nonbank providers of (1) money-transfer services for incarcerated people and their loved ones and (2) prepaid cards for people being released from prison or jail, known as “debit release cards” or “release cards.”
Comments re: Bureau of Prisons' Proposed Rule on "Reservation of Funds for Reentry Under the First Step Act"
NCLC submitted comments, co-authored by the Fines and Fees Justice Center and joined by five other organizations, in response to the Bureau of Prisons’ (“BOP”) Proposed Rule on “Reservation of Funds for Reentry Under the First Step Act.” In these comments, we argue that the BOP must revise its Proposed Rule to better accord with…
Reply Comments to the FCC Regarding Implementation of the Martha Wright-Reed Act (with the Wright Petitioners)
NCLC joined reply comments to the Federal Communications Commission (FCC) regarding incarcerated people’s communications services, implementation of the Martha Wright-Reed Act, and rates for interstate inmate calling services. Among other things, the Martha Wright-Reed Act directs the FCC to ensure that companies providing communication services to people who are incarcerated are no longer able to…
Landlords in the United States almost always engage in some form of screening for rental applicants. Each of the components of tenant screening reports is highly problematic and also creates a disparate impact on Black and Latino renters. The manner in which the components are combined to generate scores or recommendations, and then used by landlords, is also harmful to renters.