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NCLC submitted comments to the New York Department of Financial Services in response to its request for information on buy now, pay later products. The comments address issues that DFS should consider when writing regulations in order to protect consumers. The BNPL Act gives DFS broad authority to promulgate rules consistent with the purposes of…
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We support HUD’s ongoing commitment to sustainable homeownership. As HUD notes, this mission is consistent with HUD’s core obligation of protecting the Mortgage Mutual Insurance Fund. Importantly, it also aligns with HUD’s statutory duty of “meet[ing] the housing needs of the borrowers that the single family mortgage insurance program under this subchapter is designed to…
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NCLC opposes Connecticut SB 1396, An Act Concerning Earned but Unpaid Wage or Salary Income Advance, which exempts earned wage advance payday loans from Connecticut’s interest rate caps.
Read More about Letter Opposing Connecticut S 1396 Earned Wage Advances
The National Consumer Law Center is among 49 groups urging Maryland Governor Moore to veto HB 1294, which would carve loopholes in Maryland’s 33% interest rate limit for earned wage advances and other fintech payday loans.
Read More about Letter Urging Veto of MD HB 1294, Earned Wage Advance
National groups urge the CFPB to issue its proposed rule codifying the application of the FTC’s Credit Practices Rule to financial institutions (Reg AA), and adopting three important new consumer protections. The proposed rule would forbid covered entities from including in their contracts 1) any clause that waives legal rights designed to protect consumers, 2)…
The National Consumer Law Center, the Center for Responsible Lending and the Student Borrower Protection Center submitted to the Office of the Comptroller of the Currency, Federal Reserve System, and Federal Deposit Insurance Corp. on the Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses. The comments focus…
Read More about Comments on Risks of Bank-Fintech Arrangements Involving Lending
Comments of the National Consumer Law Center, on behalf of its low-income clients and Consumer Action, Consumer Federation of America, National Association of Consumer Advocates, National Consumers League, Open Markets Institute, and U.S. PIRG regarding a case where Federal Trade Commission (FTC) uncovered evidence that three major rent-to-own (RTO) players engaged in a market allocation…
Read More about Comments to the FTC in the Matter of Rent-to-Own Store Swaps
These joint comments support an interpretive rule proposed by the CFPB that would clarify that earned wage advance products are credit transactions.
The undersigned consumer, labor, civil rights, legal services and community organizations write in strongsupport of the Consumer Financial Protection Bureau’s proposed interpretive rule on emerging paycheckadvance products, sometimes marketed as “earned wage” products. Workers should not have to pay to be paid, and we support the CFPB’s efforts to guard against predatory lending in the…
The 90 undersigned consumer, civil rights and community organizations and academics submit these comments on the Consumer Financial Protection Bureau’s Interpretive Rule regarding buy now pay later (BNPL) credit. We support the CFPB’s conclusion that accounts used to access BNPL credit are credit cards that must comply with credit card rules governing disputes, errors, periodic…
Consumer Reports and the National Consumer Law Center, on behalf of its low-income comments, submitted comments on the Consumer Financial Protection Bureau’s (CFPB) proposed Interpretive Rule under the Truth in Lending (Regulation Z) on Use of Digital User Accounts to Access Buy Now, Pay Later Loans. As we described more fully in response to the…
Consumer and labor organizations submitted comments to the California Department of Financial Protection and Innovation urging DFPI to update the proposed regulations for earned wage advances to require providers to comply with California’s interest rate limits.
Read More about Comment on California Earned Wage Advance Regulation