These comments were submitted in response to the Federal Trade Commission’s Notice of Proposed Rulemaking published on December 17, 2012, regarding the agency’s Used Car Rule. The existing rule, which was promulgated in 1985, was fundamentally flawed from its inception, and is now also antiquated. Parts of it — particularly the language interpreting what ”…
Read More about Group Comments to the FTC Opposing its Used Car Rule
For three centuries or more, the common law has prohibited contract provisions that impose a penalty greater than the amount of damages caused by a breach of the contract. When those damages are difficult to determine, the common law permits “liquidated damages” provisions that are reasonably related to the actual damages sustained by the party.…
These comments are submitted by the National Consumer Law Center (on behalf of its low-income clients), as well as the Center for Responsible Lending, Consumer Action, Consumer Federation of America, Consumers Union, Empire Justice Center, New York Legal Assistance Group, and the Sergent Shriver Center on Poverty Law. The comments address the Federal Reserve Board’s…
Over 17 million Americans are unbanked, relying on alternative, and often costly, financial services providers. Policymakers, consumer advocates and the banking industry are increasingly working to move people into the financial mainstream by promoting basic banking accounts. Prepaid cards have also been promoted as safe alternative transaction account. Indeed, the bank account and prepaid models…
Read More about Features of a Safe Basic Banking or Prepaid Card Account
Credit cards have long been a source of confusion for consumers and a tool of manipulation for many card issuers. The Credit Card Accountability, Responsibility and Disclosure Act of 2009 (Credit CARD Act) created long needed protections for cardholders. But the Act did not eliminate all dangerous aspects of credit cards or every unfair or…
Read More about Beyond the Credit CARD Act: Features of a Safer Credit Card
While financial crisis and recession have wreaked havoc on the American economy, the pain has been especially intense for consumers. Millions are now burdened with unpayable debts after they were enticed into borrowing during the credit boom.