The National Consumer Law Center (on behalf of its low-income clients) and Consumer Federation of America, Consumers Union, Main Street Alliance, and U.S. PIRG thank you for the opportunity to comment on the Office of the Comptroller of the Currency’s (OCC’s) white paper on Exploring Special Purpose National Bank Charters for Fintech Companies. We appreciate…
The undersigned consumer, community, civil rights and legal services groups submit these comments in response to the Consumer Financial Protection Bureau (“CFPB”)’s Request for Information (“RFI”) regarding its inherited regulations and rulemaking authorities. These comments focus on electronic communications generally, including electronic disclosures, statements and records. Many of our organizations have also joined other comments…
This written testimony is submitted on behalf of the National Consumer Law Center in support of Md. H.B. 42 / S.B. 106, which would amend Md. Code, Comm. Law § 11-504 to create a self-executing $500 bank account protection that will shield that minimal amount from seizure by creditors. Enacting this legislation is an important…
Read More about Testimony in Support of Legislation to Improve State Exemption Laws in Maryland
This written testimony is submitted on behalf of the National Consumer Law Center in support of S.B. 5173, which would amend RCW 6.15.010 to increase protections for financially-stressed families in the state. This would be an important step toward strengthening Washington’s overall property protections for families struggling with debt.
NCLC and the National Community Reinvestment Coalition submit comments that fall into two categories. We agree with the Federal Reserve’s intention to provide greater clarity on how it will evaluate applications. But we remain opposed to the possibility of accounts for the uninsured institutions in Tier 2 and Tier 3, which will permit evasions of…
We support the proposed rule but have a number of recommendations, including adding protections to protect distressed borrowers and prevent the misuse of escrow account refunds; removing repayment-plan payments from the definition of “monthly payment” used for the seasoning rule; and working with Congress to determine whether statutory changes are necessary to prevent other abuses…
NCLC’s comments focus on the relationship between DCWP’s proposed amendments, the federal Fair Debt Collection Practices Act (“FDCPA”), and federal debt collection regulations issued to implement the FDCPA (“Regulation F”). Regulation F has many gaps and weaknesses, and we commend the DCWP’s proposal for its efforts to fill some of these gaps.