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Comments on the Application to Charter OppFi National Bank & Acquire BNC Bank

July 31, 2026

NCLC, on behalf of our low-income clients, and 134 consumer, civil rights, legal services and community groups, and academics submitted comments to the Federal Deposit Insurance Corp.(FDIC), Office of the Comptroller of the Currency (OCC), and Board of Governors of the Federal Reserve System (FRB) on the application of Opportunity Financial (“OppFi”) to become a…

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Coalition Letter to Federal Reserve Requesting Full Board Vote and Public Hearing on Applications of Enova and Opportunity Financial to Become Bank Holding Companies

June 22, 2026

The Board of Governors is presently reviewing the application of Enova International to acquire Grasshopper Bank and to become a bank holding company. The Board is also expected to shortly receive the announced application of Opportunity Financial (“OppFi”) to acquire BNC Bank and to become a bank holding company. In light of the unprecedented nature…

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Coalition Letter Opposing Unaffordable 100% APR Bank Loans; Urging Congress to Support State and Federal Interest Rate Limits

May 7, 2026

The 106 undersigned consumer, civil rights, and community organizations wrote to Chairman Scott, Ranking Member Warren, Chairman Hill and Ranking Member Waters urging them to defend and strengthen interest rate limits and transparency to address the affordability crisis by:

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Letter from Civil Rights Groups to Federal Reserve Board Opposing Enova Bank Charter

April 22, 2026

Civil rights and consumer advocacy organizations wrote to the Federal Reserve Board to lodge objection to the merger application of Enova International, Inc. (Enova) and Grasshopper Bank and to request a meeting. Objections arise specifically under the Federal Reserve’s review authority under the Bank Holding Company Act (BHCA), which requires consideration of financial resources, managerial…

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Comments on the Application to Charter Enova Interim Bank & Acquire Grasshopper Bank

February 27, 2026

NCLC, on behalf of our low-income clients, submitted comments on the application to the Office of the Comptroller of the Currency (OCC) and to the Federal Reserve Board (Fed) to charter Enova Interim Bank and to acquire Grasshopper Bank, NA. The OCC and Fed should deny Enova’s application. At a time when President Trump is…

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Letter Supporting Close the Shadow Banking Loophole Act

January 29, 2026

NCLC joined banking and consumer organizations in thanking Senators Kennedy and Kim for introducing the Close the Shadow Banking Loophole Act, which would close the industrial loan company (ILC) loophole in current law. In light of recent approvals by the FDIC of ILC applications for Ford Motor Company and General Motors Company, as well as…

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Comment Letter to OCC in Opposition to First National Digital Currency Bank Charter Application

July 30, 2025

NCLC joined various consumer organizations in a letter opposing the application by Circle Internet Group, Inc. (“Circle”) for a national trust bank charter under the name First National Digital Currency Bank, N.A. (“FNDCB”). Circle is a stablecoin issuer seeking to obtain a national bank charter. Granting a national trust bank charter to any stablecoin issuer…

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Letter Supporting S.3538, the Close the Shadow Banking Loophole Act

December 15, 2023

NCLC supports the Close the Shadow Banking Loophole Act, which would close the industrial loan company loophole that enables companies to obtain a bank charter and the privileges of a bank, including preemption, without the full oversight and obligations of other banks.

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Comments to FDIC Regarding False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC's Name or Logo

April 6, 2023

The National Consumer Law Center (on behalf of its low-income clients), Americans for Financial Reform Education Reform Fund, Consumer Reports, Student Borrower Protection Center, Public Justice Center, Public Good Law Center, U.S. PIRG, Consumer Federation of America, and Better Markets submitted comments regarding the Federal Deposit Insurance Corporation’s (FDIC) recent proposed changes to part 328…

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Letter to CFPB Regarding Repeat Offenders; Registry of Nonbank Financial Companies Subject to Certain Agency and Court Orders

March 31, 2023

Submitted to Regulations.govRohit Chopra, DirectorConsumer Financial Protection Bureau1700 G Street NW,Washington, DC 20552 Dear Director Chopra, The undersigned consumer organizations are pleased to support the Consumer Financial Protection Bureau’s (CFPB) proposal to require nonbank covered persons that are subject to certain agency and court orders to register those orders with the CFPB. The registry will…

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Coalition Comments to FDIC Regarding Community Reinvestment Act Examination of First Electronic Bank

March 21, 2023

Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low- income clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submitted comments for the Community Reinvestment Act (CRA) examination of First Electronic Bank. First Electronic Bank helps…

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Coalition Comments to FDIC Regarding Community Reinvestment Act Examination of Rent-a-Bank FinWise Bank

March 14, 2023

Accountable.US, Americans for Financial Reform, Center for Responsible Lending, Consumer Action, Consumer Federation of America, National Consumer Law Center (on behalf of its low-income clients), National Community Reinvestment Coalition, Public Citizen, US PIRG and the Woodstock Institute submitted comments in connection with the Community Reinvestment Act (CRA) examination of FinWise Bank. FinWise Bank helps several…

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