Comments Archives

Americans for Financial Reform Coalition Comment to CFPB on PACE Rulemaking

July 26, 2023

Americans for Financial Reform Education Fund, along with 20 organizations in the housing, consumer protection, climate and environmental justice, and community investment spaces, submitted comments on the Consumer Financial Protection Bureau (CFPB)’s proposed rule on residential Property Assessed Clean Energy (PACE) financing. The comment urges the CFPB to finalize this rule swiftly to protect consumers.…

Reply Comments to the FCC Regarding Consent for Telemarketing Calls

June 6, 2023

Follow up comments on consent requirements for telemarketing calls, pointing out that lead generators and other “consent farms” have been illegally collecting and trading purported consent agreements for these calls, and that if the FCC issues guidance like that issued by the FTC, most of the billion-plus telemarketing calls made every month would likely stop.

Consumer and Privacy Group Comments to FCC Regarding Consent for Telemarketing Calls

May 8, 2023

Comments filed by NCLC on behalf of eleven national consumer and privacy organizations urging the FCC to issue guidance stating the existing regulations governing agreements for consent and permission for prerecorded telemarketing calls to cell phones and landlines, and all telemarketing calls to lines on the DNC registry can only relate to calls from one seller…

Comments to the CFPB on Property Assessed Clean Energy (PACE) Financing Proposed Rule

July 26, 2023

NCLC and NHLP submitted comments in strong support of the CFPB’s proposed consumer protection regulations for PACE loans, with recommendations to strengthen the proposal and help it more fully meet its goals.

NCLC Comments to Education Department Regarding Intent to Establish Rulemaking Committee on Student Debt Relief

July 20, 2023

The National Consumer Law Center (on behalf of its low-income clients), submitted comments in response to the U.S. Department of Education’s announcement of its intent to establish a negotiated rulemaking committee to prepare regulations on federal student loan debt relief, as authorized under the Higher Education Act of 1965 (HEA). In these comments, NCLC recommends…

NCLC Request for CFPB to Limit Arbitration of FCRA Lawsuits

July 14, 2023

The National Consumer Law Center urges the Consumer Financial Protection Bureau (CFPB) to address how forced arbitration clauses in credit monitoring contracts are being used by consumer reporting agencies (CRAs) to compel arbitration of Fair Credit Reporting Act lawsuits. NCLC urges the CFPB to address this issue in its forthcoming FCRA rulemaking by prohibiting the…

Comments to CFPB RFI on Data Brokers

July 14, 2023

The data broker industry is a $240 billion industry that is growing, opaque, intrusive, and potentially harmful to consumers, yet largely unregulated. The Fair Credit Reporting Act (FCRA) presents a meaningful avenue to address this regulatory gap for many companies in this industry, if the CFPB issues a rule that defines the scope of the…

Reply Comments to the FCC Regarding Implementation of the Martha Wright-Reed Act (with the Wright Petitioners)

July 12, 2023

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…

Joint Reply Comments to FCC Regarding Implementation of the the Martha Wright-Reed Act (with Leadership Conference)

July 12, 2023

NCLC joined reply comments to the Federal Communications Commission (FCC), submitted on July 12, 2023, regarding the FCC’s implementation of the Martha Wright-Reed Just and Reasonable Communications Act of 2022. 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…

Comments to Nacha on Measures to Reduce Fraudulently-Induced Credit Push ACH Payments

June 30, 2023

NCLC submitted comments to Nacha in response to a request for information on potential changes to Nacha rules to address the management of fraud. The comments urged Nacha to require the banks that hold accounts of fraudsters to monitor the rate at which consumers request return of funds and to keep those return rates below…

Abusive Acts and Practices: Comments to CFPB

July 3, 2023

NCLC joined other consumer organizations in supporting the CFPB’s statement of policy regarding the prohibition on abusive acts and practices and submitted comments outlining a number of types of abusive practices, which impact wide swaths of American consumers and have an especially negative impact on vulnerable and marginalized communities.

NCLC and CRL Comments to HUD's Proposed Payment Supplement Partial Claim

June 30, 2023

In these comments, the National Consumer Law Center and the Center for Responsible Lending provided detailed comments to HUD’s proposed Payment Supplement Partial Claim program, which will help borrowers avoid unnecessary foreclosure.

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