Resources Archive

90 Consumer, Civil Rights and Community Organizations and Academics Comments to CFPB Regarding Buy Now, Pay Later Loans Interpretive Rule

August 1, 2024

The 90 undersigned consumer, civil rights and community organizations and academics submit these comments on the Consumer Financial Protection Bureau’s Interpretive Rule regarding buy now pay later (BNPL) credit. We support the CFPB’s conclusion that accounts used to access BNPL credit are credit cards that must comply with credit card rules governing disputes, errors, periodic…

NCLC & Consumer Reports Comments to CFPB Regarding Buy Now, Pay Later Loans Interpretive Rule

August 1, 2024

Consumer Reports and the National Consumer Law Center, on behalf of its low-income comments, submitted comments on the Consumer Financial Protection Bureau’s (CFPB) proposed Interpretive Rule under the Truth in Lending (Regulation Z) on Use of Digital User Accounts to Access Buy Now, Pay Later Loans. As we described more fully in response to the…

Comments on Interagency Guidance Regarding Unfair or Deceptive Credit Practices

October 27, 2014

The National Consumer Law Center, on behalf of its low-income clients, the Center for Responsible Lending, Consumer Action, the Consumer Federation of America, the National Association of Consumer Advocates, the New Economy Project, and U.S. PIRG, write to comment on the issuance of the Interagency Guidance regarding Unfair or Deceptive Credit Practices (“Guidance”) and the…

Comment on California Earned Wage Advance Regulation

July 24, 2024

Consumer and labor organizations submitted comments to the California Department of Financial Protection and Innovation urging DFPI to update the proposed regulations for earned wage advances to require providers to comply with California’s interest rate limits.

Letter Urging OCC to Rescind Preemption Regulations

July 19, 2024

NCLC, joined by several consumer organizations, sent a letter urging the Office of the Comptroller of the Currency (OCC) to immediately rescind the OCC’s rules, interpretations, bulletins and opinions preempting state consumer financial laws, as they are not in compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 or the Supreme…

Texas Comment Letter to FEMA on Equity Interim Final Rule

July 22, 2024

This comment provides input a wide range of FEMA policies that could increase equitable access to disaster relief for the hardest hit disaster survivors, including the need to improve procedures for heirs property owners and others with non-traditional homeownership.

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