Comments Archives

Group Comments to FTC Regarding Unfair or Deceptive Fees Affecting Justice-Involved Individuals

February 8, 2023

The undersigned civil rights, consumer rights, faith-based, criminal justice, and reentry organizations respectfully submitted the following comments in response to the Federal Trade Commission’s (FTC) Advance Notice of Proposed Rulemaking (“ANPR”) regarding unfair or deceptive fees, R207011.1 These comments discuss junk fees affecting justice-involved people. The organizations urge the Commission to identify and confront the…

Coalition Comments to the Task Force on New Americans on Expanding Language Access Within the Financial Services Sector

February 7, 2023

Comments submitted on behalf of civil rights and consumer advocacy organizations regarding the request for public input issued by the Financial Access and Education Subcommittee of the White House Task Force on New Americans. The consumer groups urge the Financial Access and Education Subcommittee to incorporate policies that would explicitly expand language access within the…

Joint Trade Letter to FHA Regarding Borrower Request for Review of Appraisal Results

February 2, 2023

On behalf of the industries, clients, and communities we represent, we write to comment onHUD’s proposed process for Mortgagees when a Borrower requests a review of the appraisalresults associated with their application for an FHA-insured mortgage. This joint industryconsumer comment sets out essential principles we see as vital for the successful developmentand deployment of a…

Coalition Comments Regarding a Proposed Mortgagee Letter on Borrower Requests for Review of Appraisal Results

February 2, 2023

The groups strongly support HUD’s plan to issue guidance on ROVs, but the proposed Mortgagee Letter needs substantial improvement. It should be revised to provide clear, strong standards for mortgagees and a uniform ROV disclosure for borrowers. Comments submitted by: Consumer Action, Long Island Housing Services, Inc., Mountain State Justice, Inc., NAACP Legal Defense and…

Comments to the Consumer Financial Protection Bureau Regarding the Credit CARD Act of 2009

February 19, 2013

Comments of the National Consumer Law Center, on behalf of our low income clients, on the Credit Card Accountability, Responsibility and Disclosure Act of 2009 (CARD Act). We join with the many other commenters who explain how the Credit CARD Act has been an enormous benefit to consumers and to responsible credit card issuers. We…

Comments to FTC Regarding the Business Opportunity Rule

January 31, 2023

Comments in response to the Federal Trade Commission’s November 25, 2022 advance notice of proposed rulemaking on the Business Opportunity Rule. This comment addresses why the Business Opportunity Rule is necessary, how the FTC is properly using its authority to review and potentially expand the scope of the Business Opportunity Rule, and how enhancing the…

Comments to the CFPB's Outline of Proposals to Implement Section 1033, Consumer Access to Financial Records, Small Biz Review

January 25, 2023

The National Consumer Law Center (on behalf of its low-income clients) (NCLC) and U.S. PIRG submit comments in response to the Consumer Financial Protection Bureau (CFPB)’s Outline of Proposals and Alternatives Under Consideration to Implement Section 1033 of the DoddFrank Act, issued pursuant to Small Business Regulatory Enforcement Fairness Act (SBREFA) on October 27, 2022.…

Comments to CFPB whether TILA preempts state business lending laws

January 20, 2023

Americans for Financial Reform Education Fund, Better Markets, California Reinvestment Coalition, Center for Responsible Lending, Community Service Society of New York, Consumer Reports, Empire Justice Center, Main Street Alliance, National Association of Consumer Advocates, National Consumer Law Center (on behalf of its low income clients), New Economy Project, Public Citizen, Small Business Majority, U.S. PIRG,…

Comments to Federal Reserve & CFPB on Remotely Created Items, Funds Availability Schedule for Prepaid Cards and Mobile Deposits

September 18, 2013

The National Consumer Law Center (on behalf of its low income clients), Consumer Action, Consumer Federation of America, Consumers Union, the nonprofit publisher of Consumer Reports, National Association of Consumer Advocates, and National Consumers League urge the Consumer Financial Protection Bureau (CFPB) and Federal Reserve Board (FRB) to: Open a rulemaking to work towards the…

Comments Urging Federal Reserve to Bank Remotely Created Checks

December 13, 2013

These comments are submitted by the National Consumer Law Center (on behalf of its low income clients), Consumer Federation of America, Center for Responsible Lending, Consumer Action, Consumers Union, National Association of Consumer Advocates, National Consumers League and U.S. PIRG. We urge the Federal Reserve Board (FRB) to ban the use of remotely created checks…

Comments to Federal Reserve Regarding 10-Year Review Under Economic Growth and Regulatory Paperwork Reduction Act

September 2, 2014

The National Consumer Law Center, on behalf of its low income clients, Center for Responsible Lending, Consumer Action, Consumer Federation of America, Consumers Union, National Association of Consumer Advocates, National Consumers League and U.S. PIRG submit these comments in response to the Federal Reserve Board’s (FRB’s) request for the public to identify regulations that are…

Comments to the OCC on Supporting Responsible Innovation in the Federal Banking System

May 31, 2016

The National Consumer Law Center®, on behalf of its low income clients, Center for Responsible Lending, Empire Justice Center and U.S. Public Interest Research Group appreciate the opportunity to submit these comments in response to the Office of the Comptroller of the Currency’s request for comments on how to support responsible financial innovation. Our comments…