Comments Archives

Coalition Comments Regarding Collection of Checks & Other Items by Federal Reserve Banks and Transfers Through Fedwire

September 9, 2021

Comments of 43 consumer, small business, civil rights, community and legal service groups on the Federal Reserve Board’s (FRB) proposed rules for implementing the FedNow payment system. We believe that an FRB real time payment system can provide competition and, if properly designed, can ensure that all consumers and businesses benefit from the widespread availability…

Coalition Comments Urging CFPB to Rescind Earned Wage Access Advisory Opinion and Sandbox Approval

October 12, 2021

The 96 undersigned consumer, labor, civil rights, legal services, faith, community and financial organizations and academics write to express concerns about the treatment of earned wage access (EWA) products. While free earned wage advances may be a better option for consumers than costly payday loans, these products are not without risks. Viewing earned wage advances,…

NCLC, SBPC, PPI Comments to Department of Education on Proposed Rules regarding Pell Grants for Incarcerated Students

August 26, 2022

We applaud many of ED’s proposals to ensure that incarcerated individuals’ renewed Pell Grant eligibility yields the most benefit to them and is not abused by predatory for-profit institutions. However, we urge ED to, at a minimum, automatically enroll all defaulted incarcerated borrowers in Fresh Start. We also urge ED to create a long-term automatic…

Joint Comment to FHA’s Defect Taxonomy of the Single Family Housing Policy Handbook

January 28, 2022

On behalf of the industries, clients, and communities we represent, the undersigned write to comment on HUD’s proposed defect taxonomy for loan servicing reviews. This joint industry-consumer comment supplements our organizations’ individual comments and sets out essential principles we see as vital in the creation of any defect taxonomy.

Group comments on OCC Notice of Proposed Rulemaking, Permissible Interest on Loans

January 20, 2020

Interest rate limits are the single most effective tool states have to protect their residents from predatory loans. Predatory loans include payday and car title loans that often carry annual interest rates as high as 300% or more. Predatory loans also include high-cost installment loans and lines of credit with rates approaching and well exceeding…

Joint Coalition Comments on the CFPB's Inquiry into Buy Now, Pay Later Credit Products

March 28, 2022

The undersigned 77 consumer, housing, civil rights, legal services, faith, community, small business, student borrower, and public interest organizations appreciate the opportunity to comment on the CFPB’s inquiry into Buy Now, Pay Later (BNPL) credit products that are proliferating across market areas. We welcome the CFPB’s recent inquiry into Affirm, Afterpay, Klarna, PayPal, and Zip,…

Longer Comment Regarding the CFPB’s Inquiry into Buy-Now-Pay-Later Providers

March 25, 2022

In response to the Request for Comments issued by the Consumer Financial Protection Bureau, Center for Responsible Lending, National Consumer Law Center (on behalf of its low-income clients), and Consumer Federation of America offer our joint recommendations for further guidance and monitoring of the growing BNPL market overall, which are specific to the “pay-in-four” model.…

Comments to Federal Reserve Board Regarding Guidelines for Evaluating Account and Service Requests

April 22, 2022

The Center for Responsible Lending, National Community Reinvestment Coalition, the National Consumer Law Center, on behalf of its low-income clients, and Arthur E. Wilmarth, Jr., Professor Emeritus of Law at George Washington University Law School appreciate the opportunity to comment on the Board of Governors of the Federal Reserve System’s (the Board) supplemental notice and…

Consumer Groups to FCC: Finish the Exemptions Proceeding as Congress Required

October 4, 2022

This ex parte Notice is submitted to describe a meeting between Federal Communications Commission staff and consumer and privacy advocates on September 30, 2022.

Comments to FinCEN Regarding Review of Bank Secrecy Act Regulations and Guidance

February 14, 2022

The National Consumer Law Center (“NCLC”) (on behalf of its low-income clients), National Community Reinvestment Coalition, and National Consumers League appreciates the opportunity to submit comments to the Financial Crimes Enforcement Center (“FinCEN”) regarding the modernization of the current Bank Secrecy Act, Anti-Money Laundering, & Counter-Financing of Terrorism (collectively, “AML”) regime. Specifically, we urge greater…

Group Comments in Support of NALA Petition of Waiver of Lifeline Mobile Broadband Minimum Standard and Voice Support Phase-Down

September 14, 2020

Lifeline, the only federal program that addresses the issue of affordability central to accessing essential communications service, is not just a crucial tool to closing the divide but has also become an essential resource for low-income people across the country during the ongoing COVID-19 pandemic. Carriers report a marked increase in voice usage during this…

Comments to the CFPB on its Supplemental Notice of Proposed Rulemaking Docket No. CFPB-2020-0010

August 4, 2020

In March 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a supplemental debt collection rulemaking to propose disclosures for consumers when debt collectors attempt to collect a time-barred debt. These proposals do not protect vulnerable consumers from abusive practices associated with the collection of time-barred debts, but instead provide cover for continued abusive…

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