Comment on Use of Independent Third-Party Providers in Connection with Claims Without Conveyance of Title (CWCOT)
This letter urges HUD to retain policy on the use of third-party vendors in order to avoid misalignment of servicer incentives.
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Comments in Response to FCC Rulemaking on Requiring Transmission of Caller's Name
Comments of NCLC, EPIC and NACA have been submitted in response to FCC Notice of Proposed Rulemaking proposing to require that certain types of calls, those with the highest level of attestation under the STIR/SHAKEN framework which the agency thinks are unlikely to have spoofed calling numbers, must have the caller’s name transmitted to the…
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Comments Supporting the CFPB Complaints System
NCLC joined a comment letter emphasizing the importance of the CFPB’s system for accepting, processing and publishing consumer complaints.
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Comments to the CFPB on the Equal Credit Opportunity Act and Regulation B Proposed Rule
The Consumer Financial Protection Bureau’s proposed rule under Regulation B runs counter to Congress’s intent when it passed the Equal Credit Opportunity Act. By removing disparate impact liability, severely narrowing the definition of discouragement, and over-regulating special purpose credit programs, the propose rule would represent a major step backwards in our civil rights regulatory framework.…
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Comments to HUD Regarding Future of the HECM and HMBS Programs and Opportunities for Innovation in Accessing Home Equity
NCLC provided comments to the Department of Housing and Urban Development (HUD) describing the importance of the federally-insured reverse mortgage program for older adults living on limited income. Federally insured reverse mortgages are a much safer option for older homeowners than alternative “equity release” products being sold by private investors with little to no government…
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Comments Supporting CFPB Consumer Complaint Intake System
NCLC joined a comment on a Paperwork Reduction Act request emphasizing the importance of the CFPB’s Consumer Complaint Intake System.
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Comments of Groups Regarding the Efficacy of STIR/SHAKEN Caller ID Authentication
NCLC and the Joint Trade Associations comment to the FCC regarding methods to improve the STIR/SHAKEN Call Authentication Framework to better protect consumers from unwanted scam and spam calls.
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2026-2028 Enterprise Housing Goals
FHFA’s proposed 2026-2028 Enterprise Housing Goals will take away affordable mortgages for up to 177,000 lower- to moderate-income families over the next three years, worsening the housing affordability crisis and fueling deeper racial and socioeconomic inequalities in who can access credit and become a first-time homeowner.
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Request for Information on Regulatory Reform on Artificial Intelligence
Comments in response to the Office of Science Technology and Policy (OSTP) September 26, 2025 Request for Information on Regulatory Reform on Artificial Intelligence (AI). Comments call for a strong national AI regulatory framework that incorporates civil rights, establishes a risk-based approach to AI regulation, and promotes AI research and development. Comments strongly oppose the…
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Coalition Comment Urging CFPB to Keep a Strong Personal Financial Data Rights Rule
This is a comment from fifty-two (52) consumer, economic justice, privacy, and advocacy groups to the Consumer Financial Protection Bureau’s (CFPB) Advance Notices of Proposed Rulemaking reconsidering its final Personal Financial Data Rights rule implementing section 1033 of the Dodd-Frank Act. The comment strongly supports the current 1033 Rule as issued in October 2024 and…
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Comments to Illinois Department of Financial and Professional Regulation on Shared Appreciation Agreements
NCLC strongly supports IDFPR’s proposed regulations to regulate shared appreciation agreements (also known as HEI loans). But we also have a number of suggestions for making the rules clearer and stronger.
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Comments to CFPB on the Legal Standard Applicable to Risk-Based Supervisory Designations
NCLC and the Consumer Federation of America submitted comments to the CFPB opposing the proposed rulemaking to define the risks to consumers that would qualify an entity for risk-based supervision. The proposed rule directly contravenes the intention of Congress to give the Bureau considerable discretion in its exercise of this supervision authority, and it attempts…