Comments Archives

Group Comments of 65 Consumer Organizations on Registry of Supervised Nonbanks That Use Form Contracts to Impose Terms and Conditions That Seek to Waive or Limit Consumer Legal Protections

April 3, 2023

The undersigned organizations support and applaud the Consumer Financial Protection Bureau’s (CFPB) proposed rulemaking to increase transparency in financial services, to the great benefit of American consumers. This rule would create a registry system for nonbank financial firms, requiring them to publicly report terms and conditions, such as forced arbitration, that have been commonly weaponized…

Coalition Comment to FHA on 203(k) Rehabilitation Mortgages, Including Energy Efficiency Loans

April 17, 2023

FHA’s 203(k) program enables individuals and families to finance and rehabilitate an aged home. In this high-demand housing market, changes to the 203(k) could increase the utilization of this loan program, especially among prospective first-time homebuyers.

Comments in Response to Request for Information Regarding the Credit Card Market, Docket No. CFPB-2017-0006

June 8, 2017

The National Consumer Law Center is pleased to submit the following comments on behalf of our low-income clients to the CFPB’s 2017 Request for Information (RFI) Regarding the Credit Card Market. The CFPB’s request for information is pursuant to the Credit Card Accountability, Responsibility and Disclosure (CARD) Act of 2009, which requires the CFPB to…

Group Comments to the Consumer Financial Protection Bureau Regarding Regulation Z, 12 C.F.R. Part 1026

January 7, 2013

The National Consumer Law Center and Consumer Action respectfully submit the following comments on behalf of its low-income clients. We welcome the opportunity to comment on the Bureau’s proposal to amend the ability-to-pay requirement of Regulation Z, 12 C.F.R. § 1026.51(a), which was promulgated pursuant to the Credit Card Accountability, Responsibility and Disclosures (CARD) Act…

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…

Legal Aid Organizations’ Comments in Response to Proposed Borrower Defense to Loan Repayment Universal Forms

April 3, 2023

As organizations that represent low-income student loan borrowers, the undersigned organizations comment on the Department of Education’s proposed borrower defense to loan repayment application form. The organizations assist low-income student loan borrowers, many of whom were harmed by unscrupulous schools that engaged in predatory conduct to make a profit off of our clients’ federal student…

Comments to the CFPB Regarding Registry of Supervised Nonbanks That Use Form Contracts to Impose Terms and Conditions That Seek to Waive or Limit Consumer Legal Protections

April 3, 2023

The undersigned organizations support and applaud the Consumer Financial Protection Bureau’s (CFPB) proposed rulemaking to increase transparency in financial services, to the great benefit of American consumers. This rule would create a registry system for nonbank financial firms, requiring them to publicly report terms and conditions, such as forced arbitration, that have been commonly weaponized…

Joint Consumer Groups Comments to the Federal Trade Commission on Guides for the Use of Environmental Marketing Claims

February 21, 2023

These comments are submitted by the following non-profit organizations, which advocate for the interests of low-income energy and utility consumers: The National Consumer Law Center, Public Citizen, the Maryland Energy Advocates Coalition, and the Pennsylvania Utility Law Project. These comments propose changes in several areas of the Green Guides, 16 C.F.R. part 260, which relate…

Comments on the USDA Rural Housing Service's Proposed Rule Regarding Mortgage Recovery Advances

March 28, 2023

On behalf of our low-income clients, the National Consumer Law Center, Center for Responsible Lending, and National Housing Law Project submitted comments on the Rural Housing Service’s (RHS) proposed rule regarding Mortgage Recovery Advances (MRA). The advocates support RHS’s use of MRA to help borrowers reinstate past due mortgage amounts and to defer principal to…

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…

Comments to the CFPB on Proposed Rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans

October 7, 2016

Joint comments were submitted by the Center for Responsible Lending, Consumer Federation of America and National Consumer Law Center.

Comments to HUD in Response to Proposed Rule Entitled Strengthening the Section 184 Indian Home Loan Guarantee Program

March 17, 2023

NCLC submitted comments to support HUD’s decision to promulgate regulations that establish the necessary framework for a successful default servicing program and that supplement the guidance established by the RESPA.

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