Comments Archives

Comment Letter to SEEC Institute's Thriving Economy Project RFI

December 4, 2025

Strong consumer protection policies and program designs should be incorporated into emerging energy efficiency and resilience projects in order to promote affordability and access. These policies support community resilience and housing security and provide a basis for stronger energy financing solutions. They also strengthen the delivery of government programs. Robust consumer protections ensure that strong…

Comments to HUD Regarding Future of the HECM and HMBS Programs and Opportunities for Innovation in Accessing Home Equity

December 1, 2025

NCLC provided comments to the Department of Housing and Urban Development (HUD) describing the importance of the federally-insured reverse mortgage program for older adults living on limited income. Federally insured reverse mortgages are a much safer option for older homeowners than alternative “equity release” products being sold by private investors with little to no government…

Comments Supporting CFPB Consumer Complaint Intake System

June 19, 2025

NCLC joined a comment on a Paperwork Reduction Act request emphasizing the importance of the CFPB’s Consumer Complaint Intake System.

Comments of Groups Regarding the Efficacy of STIR/SHAKEN Caller ID Authentication

November 18, 2025

NCLC and the Joint Trade Associations comment to the FCC regarding methods to improve the STIR/SHAKEN Call Authentication Framework to better protect consumers from unwanted scam and spam calls.

2026-2028 Enterprise Housing Goals

November 3, 2025

FHFA’s proposed 2026-2028 Enterprise Housing Goals will take away affordable mortgages for up to 177,000 lower- to moderate-income families over the next three years, worsening the housing affordability crisis and fueling deeper racial and socioeconomic inequalities in who can access credit and become a first-time homeowner.

Request for Information on Regulatory Reform on Artificial Intelligence

October 26, 2025

Comments in response to the Office of Science Technology and Policy (OSTP) September 26, 2025 Request for Information on Regulatory Reform on Artificial Intelligence (AI). Comments call for a strong national AI regulatory framework that incorporates civil rights, establishes a risk-based approach to AI regulation, and promotes AI research and development. Comments strongly oppose the…

Coalition Comment Urging CFPB to Keep a Strong Personal Financial Data Rights Rule

October 21, 2025

This is a comment from fifty-two (52) consumer, economic justice, privacy, and advocacy groups to the Consumer Financial Protection Bureau’s (CFPB) Advance Notices of Proposed Rulemaking reconsidering its final Personal Financial Data Rights rule implementing section 1033 of the Dodd-Frank Act. The comment strongly supports the current 1033 Rule as issued in October 2024 and…

Comments to Illinois Department of Financial and Professional Regulation on Shared Appreciation Agreements

October 15, 2025

NCLC strongly supports IDFPR’s proposed regulations to regulate shared appreciation agreements (also known as HEI loans). But we also have a number of suggestions for making the rules clearer and stronger.

Comments to CFPB on the Legal Standard Applicable to Risk-Based Supervisory Designations

September 25, 2025

NCLC and the Consumer Federation of America submitted comments to the CFPB opposing the proposed rulemaking to define the risks to consumers that would qualify an entity for risk-based supervision. The proposed rule directly contravenes the intention of Congress to give the Bureau considerable discretion in its exercise of this supervision authority, and it attempts…

Group Comments to CFPB Opposing a Reduction in the Number of Companies Deemed Larger Participants

September 22, 2025

The undersigned groups submit these comments on the Consumer Financial Protection Bureau’s (CFPB) four advance notices of proposed rulemaking (ANPR) on whether to propose a rule to change the definition of larger nonbank participants in the auto finance, debt collection, credit reporting and international money transmission markets. The ANPRs suggest that the number of companies…

Comments to the CFPB Regarding Defining Larger Participants of the Remittances Market

September 22, 2025

The National Consumer Law Center (on behalf of its low-income clients) and Consumer Federation of America submit these comments on the Consumer Financial Protection Bureau’s advance notice of proposed rulemaking (ANPR) on whether to propose a rule to amend the test to define larger nonbank participants in the international money transfer (remittances) market. Entities defined…

Slamming/Cramming (Truth-in-Billing) Comments to the FCC

September 22, 2025

These are comments prepared by NCLC and signed on to by Media Justice, Public Knowledge and United Church of Christ Media Justice Ministry in the FCC’s proceeding to modernize their slamming and cramming rules. The comments provide recommendations on how the Commission can strengthen their rules to protect consumers in the modern communications marketplace. The…

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