NCLC, CRL & CFA Comments in Support of CFPB’s Proposed Interpretive Rule on Earned Wage Advances
These joint comments support an interpretive rule proposed by the CFPB that would clarify that earned wage advance products are credit transactions.
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165 Organizations and Academics Support the CFPB’s Paycheck Advance Interpretive Rules
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…
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Comments on FHA Defect Taxonomy
NCLC submitted comments on HUD’s revised version of the Defect Taxonomy, which is a document that will be used when HUD assesses servicer compliance with FHA-insured rules.
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Comment on Form EIA-112: Residential Utility Disconnections Survey
NCLC and partner organizations submitted a comment to the U.S. Department of Energy/Energy Information Administration (EIA) supporting the EIA proposal to require certain electric and gas utilities to report and make public monthly residential service disconnections data. To support racial justice objectives, NCLC and commenters recommended that disconnections data be reported at the zip code…
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Maryland Energy Efficiency Advocates Supplemental Comments Re: Low-Income Affordability Mechanism
Supplemental comments were filed from the Maryland Energy Efficiency Advocates to the Maryland Public Service Commission in response to the commission’s additional questions regarding the design of a low-income affordability mechanism.
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Comments to the Department of Treasury on Use of Artificial Intelligence in Financial Services
Use of artificial intelligence in financial services has the potential to reduce costs, increase efficiency in the underwriting process, detect fraud, and improve customer relations. However, the use of complex, opaque algorithmic models in consumer credit and banking transactions also heightens the risk of unlawful discrimination, and unfair, deceptive, and abusive practices.
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NCLC Comments Supporting CFPB Proposal to Ban Medical Debt From Credit Reports
These are NCLC’s detailed comments supporting the CFPB’s Notice of Proposed Rulemaking to ban medical debt from credit reports. The comments discuss the research and evidence to support the proposed rule, including the fact that medical debt disproportionately affects communities of color as well as consumers with disabilities. The comments also analyze why the CFPB…
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NCLC Petition for Rulemaking under the Equal Credit Opportunity Act to Protect Renters
This is a petition urging the CFPB to open a rulemaking under the Equal Credit Opportunity Act (ECOA) to define residential real estate leases as “credit” and landlords as “creditors” under the ECOA for two limited purposes:
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107 Advocacy Groups Comments Supporting CFPB Medical Debt Credit Reporting Ban Proposal
These are comments from 107 consumer, health care, civil rights, faith-based, economic development, legal services, and advocacy organizations supporting the Consumer Financial Protection Bureau’s proposed rule banning medical debt from credit reports. The proposed rule will benefit the 15 million consumers unfairly burdened by medical debt on their credit reports, disproportionately affecting Black and Latino…
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Petition to the CFPB for FCRA Rulemaking on Coerced Debt
NCLC and CSAJ submit this petition for rulemaking under the FCRA to the CFPB asking the Bureau to:
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NCLC Comments to CFPB on Fees Imposed in Residential Mortgage Transactions
Closing costs are an expensive and confusing part of obtaining a mortgage. While addressing these issues can have some effect on entrance into the homeownership market and can also affect the cost of refinancing into a more affordable monthly payment, the Bureau should also focus on other more significant barriers to affordable homeownership, such as…
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90 Consumer, Civil Rights and Community Organizations and Academics Comments to CFPB Regarding Buy Now, Pay Later Loans Interpretive Rule
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…