Comments Archives

Testimony in Support of Legislation to Improve State Exemption Laws in Maryland

January 17, 2023

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…

Testimony in Support of Legislation to Improve State Exemption Laws in Washington State

January 17, 2023

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.

Comments to Federal Reserve Regarding Proposed Guidelines Evaluating Account and Services Requests

January 17, 2023

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…

Comments regarding Loan Guaranty: Revisions to VA-Guaranteed or Insured Interest Rate Reduction Refinancing Loans

January 3, 2023

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…

Consumer Groups Comments to the CFPB Regarding the Need for Additional Auto Finance Data

December 19, 2022

In comments submitted by the Americans for Financial Reform Education Fund, Consumer Action, Consumer Federation of America, Consumers for Auto Reliability and Safety, Center for Responsible Lending, National Association of Consumer Advocates, National Consumer Law Center, on behalf of our low-income clients, UnidosUS and U.S. PIRG, we applaud the Consumer Financial Protection Bureau (“CFPB” or…

Coalition Comments to CFPB Regarding Collection of Data from the Auto Finance Market

December 19, 2022

Auto credit and cars in general have an enormous impact on the majority of households, and auto credit is the third largest consumer credit market in the United States. Yet publicly available data is minimal and often excludes important portions of the marketplace and important details of the transactions—details that impact performance of the credit…

Comments Regarding New York City's Proposed Amendments to Rules Related to Debt Collectors

December 19, 2022

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.

Housing Advocates' Comment to Federal Insurance Office on Climate Risk Data Call

December 20, 2022

Americans for Financial Reform Education Fund, Consumer Federation of America, California Reinvestment Coalition, and the National Consumer Law Center write to indicate our strong support for the Federal Insurance Office’s (FIO) proposed “Climate-Related Financial Risk Data Collection” from insurers.

Consumer Groups to FTC: Stop Impersonation of Government and Business Caller

December 16, 2022

The proposed trade regulation rule will more clearly address imposter scams in which the scammers impersonate government, businesses, or their officials.

Reply Comments to the FCC Regarding Unwanted and Illegal Text Messages

December 9, 2022

The National Consumer Law Center (NCLC) and the Electronic Privacy Information Center (EPIC), along with sixteen other national and state consumer and privacy groups representing a broad swath of individual telephone subscribers across the United States, urge the Federal Communications Commission (FCC) to stand firm against requests to force cell phone carriers to allow unwanted…

Group Long Comments to CFPB on its Proposed Debt Collection Rule

September 18, 2019

The National Consumer Law Center (on behalf of its low income clients), Americans for Financial Reform Education Fund, Consumer Federation of America, National Association of Consumer Advocates, U.S. PIRG, and Woodstock Institute submit these comments on the Consumer Financial Protection Bureau‘s (CFPB or Bureau) proposed debt collection rule. We are terribly disappointed with the proposed…

NCLC's Comments to HUD regarding Small Dollar Lending

December 5, 2022

The National Consumer Law Center submitted comments to the U.S. Department of Housing and Urban Development (HUD) regarding the lack of availability of small-dollar mortgages for consumers seeking funding to purchase or repair lower priced homes. The scarcity of these types of mortgages had a disparate impact on consumers of color who were forced to…

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