Comments Archives

EPIC & NCLC file comprehensive comments asking the FCC to force the telephone service providers who provide access to the telephone system for illegal robocallers to be held accountable for their actions

October 14, 2021

We applaud the Commission’s initiation of a regulatory process to consider the best ways to increase accountability for VoIP providers by limiting their direct access to numbers pursuant to Section 6 of the TRACED Act. That section requires the Commission to determine “how Commission policies regarding access to number resources . . . could be…

Short Coalition Comments to OCC Regarding Proposed Rule to Gut Longstanding True Lender Doctrine

September 3, 2020

The undersigned 101 community, consumer, civil rights, and faith organizations vigorously oppose the OCC’s proposed rule to gut the longstanding “true lender” anti-evasion doctrine. The proposed rule would trample state interest rate limits and unleash predatory lending in all 50 states, further exacerbating the economic impacts already experienced by COVID-19.

Legal Aid Coalition Comments to the Department of Education Regarding Intent to Establish Negotiated Rulemaking Committee: Title IV of the HEA

July 1, 2021

On behalf of our low-income clients and organizations across the country that provide free legal assistance to low-income student loan borrowers, the undersigned 38 legal services organization submitted these comments to address the U.S. Department of Education’s notice of intent to establish negotiated rulemaking committees to prepare proposed regulations for programs authorized under title IV…

Comments on Prepaid Accounts Under the EFTA and TILA

March 23, 2015

National Consumer Law Center, on behalf of its low income clients, submit the attached comments on the rules proposed by the Consumer Financial Protection Bureau (CFPB) to protect prepaid cards under the Electronic Funds Transfer Act and the Truth in Lending Act. We support the CFPB’s proposal to extend to prepaid cards the critical protections…

Group Comments to the OCC Regarding “National Banks and Federal Savings Associations as Lenders”

September 3, 2020

Comments in opposition the Office of the Comptroller of the Currency’s (OCC) proposed rule preempting the authority of states and courts to look beyond contrivances to the truth to prevent evasions of state usury laws. The proposal would eliminate state interest rate limits for nonbank predatory lenders in every state as long as a bank’s…

Group Comments on Energy Conservation Standards for Consumer Furnaces

October 6, 2022

Comments of the National Consumer Law Center, Alliance for Affordable Energy, Pennsylvania Utility Law Project, Consumer Federation of America, Southface, Massachusetts Energy Director’s Association, Green Energy Consumers Alliance, Georgia Watch, North Carolina Justice Center, Texas Legal Services Center, Consumers Council of Missouri, Wildfire, Renew Missouri and Virginia Citizens Consumer Council re: Docket EERE-2014–BT-STD-0031/RIN 1904-AD20 Energy…

Comments on Amendment Four of Tennessee’s TennCare III Demonstration Application

October 6, 2022

Comments to the U.S. Department of Health and Human Services In previous comments filed on September 8, 2021, NCLC raised several concerns about aspects of the proposed TennCare III waiver, i.e., that the Tennessee Medicaid program should not waive the 90-day retroactive eligibility period for Medicaid applicants, should not be designed as a block grant,…

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…

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