Resources Archive

Updated NCLC and CRL Comments on HUD's Payment Supplement Partial Claim

December 12, 2023

In these comments, the National Consumer Law Center and the Center for Responsible Lending provided detailed comments to HUD’s revision of its Payment Supplement Partial Claim program, which will help borrowers avoid unnecessary foreclosure. See here for the comments submitted on the prior version of HUD’s Payment Supplement Partial Claim.

Coalition Comment Letter to Federal Insurance Office on Climate-Related Data Collection

December 4, 2023

This coalition letter from over 30 groups urges the FIO to finalize a proposed data collection without further changes to ensure granular data collection on the impacts of climate on financial risk in insurance markets. The proposal, which at its inception was already too narrow, has been further narrowered to omit many key markets and…

Coalition Letter to Federal Housing Finance Agency Supporting Retention of Loan Purchase Targets for Duty to Serve

December 6, 2023

This letter from the Underserved Mortgage Markets Coalition to FHFA Director Sandra Thompson recommends that the Government Sponsored Enterprises should retain loan purchase targets for underserved populations even in adverse market conditions.

Letter from 60 Groups: Do Not Delay FCRA Rulemaking

December 4, 2023

NCLC submitted a letter, along with 60 consumer, civil rights, health care, and advocacy organizations, urging CFPB Director Chopra not to delay the CFPB’s planned FCRA rulemaking. This letter responds to a November 17, 2023 letter sent by 15 industry trade organizations urging Director Chopra to slow down the FCRA rulemaking by issuing an Advanced…

Comments Regarding New York City’s 2023 Proposed Amendments to Rules Related to Debt Collectors

November 29, 2023

NCLC’s comments focus on the relationship between New York City’s Department of Consumer and Worker Protections (“DCWP”) proposed debt collection amendments, the federal Fair Debt Collection Practices Act (“FDCPA”), and federal debt collection regulations issued to implement the FDCPA (“Regulation F”). Regulation F has many gaps and weaknesses, and we commend the DCWP’s proposal for…

Letter to President Biden and CFPB Supporting Lower Credit Card Late Fees

November 28, 2023

President Joe BidenThe White House1600 Pennsylvania AvenueWashington DC 20500 Mr. Rohit Chopra, DirectorConsumer Financial Protection Bureau1700 G St. NWWashington, DC 20552 Ms. Lael Brainard, DirectorMr. Michael Negron, Special Assistant to the President for Economic PolicyNational Economic Council1600 Pennsylvania Avenue NWWashington, DC 20500 Dear President Biden, Director Chopra, Director Brainard and Special Assistant Negron, The undersigned…

Letter to the FHFA regarding mortgages for new homes backed by the GSE to meet updated energy codes

November 30, 2023

The 78 undersigned affordable housing, consumer, health, energy efficiency, environmental, andbusiness organizations urge the FHFA to require that all mortgages for new homes backed by theGovernment Sponsored Enterprises (Enterprises) meet the energy code requirements currentlyproposed by the Department of Housing and Urban Development (HUD) and the U.S. Department ofAgriculture (USDA) for their mortgage products.

Letter Opposing H.R. 7428 (Steil), Earned Wage Access Consumer Protection Act

April 16, 2024

The 192 undersigned labor, civil rights, consumer, legal services and community groups and academics write to express our opposition to HR 7428 (Steil), the Earned Wage Access Consumer Protection Act. In the guise of offering protections, the bill obscures its true effect: to exempt fintech cash advances from the Truth in Lending Act, to endorse…

Comments to Calif. DFPI on Revised Earned Wage Advance Regulations

November 27, 2023

The Center for Responsible Lending, Consumer Federation of California, National Consumer Law Center, and Office of Kat Taylor submitted comments to the California Department of Financial Protection and Innovation on its revised proposed regulations of income-based advances. The DFPI’s regulatory proposal for income-based advances recognizes, rightly, that these products must be regulated as credit. This…

MEMO re: State weatherization landlord tenant agreements

June 26, 2009

Issue: I. Do states’ landlord tenant agreements include provisions that encourage the benefits of weatherization to flow primarily to tenants? II. Which states provide the strongest model for safeguarding the goals and intended beneficiaries of weatherization? Brief Answer: I. Assessment of landlord tenant agreements in twenty states indicates that the majority of agreements include provisions…

Predatory Installment Lending in the States: How Well Do the States Protect Consumers Against High-Cost Installment Loans? (2023)

November 21, 2023

Forty-five states and the District of Columbia (DC) currently cap interest rates and loan fees for at least some consumer installment loans, depending on the size of the loan. However, the caps vary greatly from state to state, and a few states do not cap interest rates at all.

Comments of Over 100 Organizations Supporting the Petition for Rulemaking to Require Meaningful Consumer Consent to Arbitration

November 14, 2023

We gratefully support and applaud the Consumer Financial Protection Bureau’s (CFPB) continued efforts to vigorously protect consumers. Our organizations, representing millions of consumers, write in support of the recent petition for a rulemaking to address the fine print trap posed by forced arbitration clauses, which give companies that violate the law a get-out-of-jail-free card, blocking…

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