Resources Archive

Comments to the CFPB Regarding Remittance Rule Assessment

May 23, 2017

The National Consumer Law Center (“NCLC”) submitted the following comments on behalf of its low-income clients and Americans for Financial Reform, Consumer Action, Consumer Federation of America, NAACP, National Association of Consumer Advocates, U.S. PIRG and Woodstock Institute. We appreciate the comprehensive nature of the CFPB’s proposed assessment plan of the Remittance Rules. However, we…

Comments to the CFPB Regarding Small Business Review Panel for Debt Collector and Debt Buyer Rulemaking

February 28, 2017

The National Consumer Law Center, on behalf of its low income clients, submitted comments on the Consumer Financial Protection Bureau’s (CFPB or Bureau) Small Business Regulatory Enforcement Fairness Act Outline of proposed regulations under the Fair Debt Collection Practices Act (FDCPA.

Testimony Responding to the Proposed Amendments to the Massachusetts Rules of Civil Procedure Regarding Credit Card Debts

February 20, 2017

Debt collection affects millions of Massachusetts residents. In 2014, the Urban Institute reported that nearly 1 in 4 Massachusetts residents with credit reports had a debt in collection due to nonpayment of a bill and that the average amount of the debt was $4,602.

Testimony of NCLC, NACA, and MLRI to the Mass. Division of Banks and the Mass. Attorney General regarding debt collection and regulation in MA

Debt collection affects millions of Massachusetts residents. In 2014, the Urban Institute reported that nearly 1 in 4 Massachusetts residents with credit reports had a debt in collection due to non-payment of a bill and that the average amount of the debt was $4,602.1

New Ways to Understand the Impact of Auto Finance on Low-Income Families

May 1, 2016

Conventional analysis of auto finance tends to ignore the number of families affected and their demographics. It also tends to obscure the rate at which new car financings are originated in comparison to other consumer debt. While economists, policymakers, and others realize the overall role that auto finance plays in the United States’ financial landscape, the scale of the impact of auto finance on those with low and moderate income, people of color, and younger people has received less attention. This report looks at existing data in new ways to better understand the true scale of auto finance for low- and moderate-income families.

Coalition Letter to the CFPB Regarding Outline of Proposed Regulations on Debt Collection

The undersigned consumer protection, civil rights, and legal services groups write to express our significant concerns with the outline of proposed regulations on debt collection issued by the Consumer Financial Protection Bureau on July 28, 2016. The proposal represents a missed opportunity to fundamentally improve protections for consumers victimized by predatory debt collection practices.

Confronting Criminal Justice Debt: The Urgent Need for Comprehensive Reform

September 2, 2016

A collaborative three-part initiative by the National Consumer Law Center and Harvard Law School’s Criminal Justice Policy Program. *** In July 2016, Philando Castile, an African-American man, was shot and killed by a police officer in Minnesota after being stopped ostensibly for driving with a cracked taillight. The shooting spurred investigation into prior interactions the…

Misaligned Incentives: Why High-Rate Installment Lenders Want Borrowers Who Will Default

July 27, 2016

OVERVIEW In a responsible loan market, the lenders’ profits are closely aligned to the successful repayment of the credit. Yet high-rate installment lending can lead to asymmetrical incentives:As long as the borrower pays long enough before defaulting, a high-rate installment loan will be profitable. If the borrower makes even half the payments on a longer term high-rate installment…

Defusing Debt: A Survey of Debt-Related Civil Legal Aid Programs in the United States

Civil legal aid organizations provide critical front-line services for low-income and elderly people across the country facing debt collection activity. Debt collection is a pervasive part of life in the United States. In 2014, 12 million adults had non-mortgage debts reported as past due on their credit reports and 77 million consumers had nonmortgage debts…

Past Imperfect: How Credit Scores and Other Analytics “Bake In” and Perpetuate Past Discrimination

February 27, 2024

Credit reports and scores reflect stunning racial disparities. Study after study has found that Black and Latino communities have lower credit scores as a group than whites and Asians. The racial disparities in credit scores are due to deep structural factors, created by centuries of intentional and legalized discrimination as well as present-day biases.

Charts & Graphics: Deceptive Bargain: The Hidden Time Bomb of Deferred Interest Credit Cards

December 16, 2015

Deceptive Bargain: The Hidden Time Bomb of Deferred Interest Credit Cards