Resources Archive

Reply Comments by National Consumer and Privacy Groups in AI Proceeding at FCC

November 15, 2024

We strongly support the FCC’s proposal to require that prior express consent for some calls that use AI must include a “clear and conspicuous disclosure that the consumer consents to receive AI-generated calls.” We also strongly support the in-call disclosure proposed by the Commission. The distinguishing characteristics of calls that should trigger the specific consent…

Revised Comments of the National Consumer Law Center on Behalf of our Low Income Clients, DPU 24-15

November 4, 2024

NCLC filed these comments with the MA Department of Public Utilities (DPU) in docket 24-15, the so-called “affordability docket.” We recommended that the DPU: (1) develop policies to reduce “energy burdens” of the lowest-income households to well below the current target of 6%; (2) ban terminations of utility service during periods of extreme heat and…

Comments to Massachusetts Division of Banks on Proposed Amendments to Debt Collection and Mortgage Servicing Rules

November 12, 2024

These comments respond to proposed amendments to the Massachusetts Division of Banks (DOB) debt collection and mortgage servicing regulations. The comments raise concerns about DOB’s proposal to replace existing regulations with federal debt collection regulations (Regulation F) and to exempt “passive debt buyers.” The comments also propose suggestions to strengthen the DOB’s mortgage servicing regulations.

Amicus Brief: PayPal v. CFPB (DC Circuit) (Prepaid Rule)

November 1, 2024

NCLC, Consumer Reports and Consumer Federation of America filed an amicus brief in the D.C. Circuit in support of the Consumer Financial Protection Bureau’s appeal of a decision finding that it was arbitrary and capricious to include PayPal’s digital wallets that hold funds in the CFPB’s rule regulating prepaid accounts.

Regulatory Publication and Review Under the Economic Growth and Regulatory Paperwork Reduction Act of 1996

October 30, 2024

The Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve (the Federal Reserve) should continue to support the fair housing regulations under their jurisdiction as they implement important areas of fair housing and fair lending law. These agencies are also urged to…

2024 Letter Urging Regulators to Protect Credit Scores of Survivors of Hurricanes Helene and Milton

October 31, 2024

Letter from 43 organizations urging CFPB, OCC, FHFA, FHA, and other federal regulators to help protect the credit reports and scores of consumers impacted by natural or declared disasters such as Hurricanes Helene and Milton

Comments on Risks of Bank-Fintech Arrangements Involving Lending

October 30, 2024

The National Consumer Law Center, the Center for Responsible Lending and the Student Borrower Protection Center submitted to the Office of the Comptroller of the Currency, Federal Reserve System, and Federal Deposit Insurance Corp. on the Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses. The comments focus…

Comments on Bank-Fintech Arrangements Impacting Payments and Deposit Accounts

October 30, 2024

NCLC submitted comments to the Office of the Comptroller of the Currency’s, the Board of Governors of the Federal Reserve System’s and the Federal Deposit Insurance Corporation on their Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses. The comments focus on the risk of bank-fintech arrangements that…

EGRPRA Comments to FDIC on Interest Rate Authority

October 30, 2024

The National Consumer Law Center, on behalf of its low-income clients, Americans for Financial Reform Education Fund, Center for Responsible Lending, Consumer Federation of America, Consumer Reports, the National Association of Consumer Advocates and Public Citizen submitted comments to the Federal Deposit Insurance Corp. in connection with the FDIC’s review of 12 CFR Part 331,…

Comments to OCC on EGRPRA Review of Preemption and Fee Regulations

October 30, 2024

In connection with the OCC’s review of regulations under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), NCLC and other consumer groups urged the OCC to rescind its preemption regulations and its “valid-when-made” interest rate regulation, and to update its national bank charges regulation.

Nursing Home Debt Collection Practices Put Residents’ Family and Friends At Risk

October 30, 2024

Even though federal law prohibits nursing homes from requiring a third party to guarantee payment of their loved one’s bill, nursing homes still frequently pursue payment from friends and family. Nursing homes have been suing residents’ children, siblings, spouses, and friends for alleged debts for decades, but advocates report increased levels of aggression in recent…

Comments on EGRPRA Review of of Bank Secrecy Act Compliance and Reports of Crimes or Suspected Crimes

October 30, 2024

The Bank Secrecy Act (BSA) regulations and the regulations regarding the filing of suspicious activity reports (SARs) are outdated and need to be updated to strengthen and modernize the anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements for financial institutions and other entities and to protect consumers. We support the proposed AML/CFT…

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