Resources Archive

Letter Urging CFPB to Rescind Earned Wage Advisory Opinion and No Action Letter

October 5, 2022

The National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending wrote to express serious concerns about two actions that the CFPB took a year ago under Director Kathy Kraninger finding that certain earned wage access (EWA) products are not “credit” under the Truth in Lending Act. These actions…

Report: 2019 Tax Season - The Return of the Interest-Bearing Refund Anticipation Loan and other Perils Faced by Consumers

October 5, 2022

Tax time is typically a time for an influx of funds for American consumers in the form of their tax refunds. This year, it was transformed into a time of uncertainty and drastic change, preceded by the longest government shutdown in history and marked by the inaugural implementation of many provisions of the Tax Cuts…

Coalition Comments Urging CFPB to Rescind Earned Wage Access Advisory Opinion and Sandbox Approval

October 5, 2022

The 96 undersigned consumer, labor, civil rights, legal services, faith, community and financial organizations and academics write to express concerns about the treatment of earned wage access (EWA) products. While free earned wage advances may be a better option for consumers than costly payday loans, these products are not without risks. Viewing earned wage advances,…

Testimony of Margot Saunders Regarding “Illegal Robocalls: Calling All to Stop the Scourge”

October 5, 2022

Americans were subjected to 5.2 billion robocalls last month–an increase by a phenomenal 370% just since December 2015.1 This explosion of robocalls invades our privacy, distracts us, disrupts our lives, costs us money, and undermines the utility of the American telephony system. The explosion of robocalls is not just a problem of calls that are…

Testimony of Margot Saunders Regarding "Legislating to Stop the Onslaught of Annoying Robocalls"

October 5, 2022

Americans were subjected to 5.2 billion robocalls last month–an increase by a remarkable 370% just since December 2015.2 This explosion of robocalls invades our privacy, distracts us, disrupts our lives, costs us money, and undermines the utility of the American telephony system. These problem robocalls are not just overt scams, such as calls made by…

Testimony of Lauren Saunders Before the U.S. House Task Force on Financial Technology on Buy Now, Pay Later and Other Fintech Cash Flow Products

October 5, 2022

We are seeing an explosion of new products allowing consumers to purchase goods and services on credit or to take advances when money runs out before payday. Some are balloon-payment loans, repaid in full with the next deposit or paycheck. Others are repaid over time, some in four installments, others over a longer time period.…

Report: Inequitable Judgments - Examining Race and Federal Student Loan Collection Lawsuits

October 5, 2022

Of the 44 million student loan borrowers, nearly one in five is currently in default on one or more federal student loans. The consequences of federal student loan default—such as wage garnishment, offset of federal benefits and tax refunds (including the Earned Income Tax Credit), and for some borrowers, a federal lawsuit—are devastating. A judgment…

NCLC, SBPC, PPI Comments to Department of Education on Proposed Rules regarding Pell Grants for Incarcerated Students

October 5, 2022

We applaud many of ED’s proposals to ensure that incarcerated individuals’ renewed Pell Grant eligibility yields the most benefit to them and is not abused by predatory for-profit institutions. However, we urge ED to, at a minimum, automatically enroll all defaulted incarcerated borrowers in Fresh Start. We also urge ED to create a long-term automatic…

Testimony of April Kuehnhoff on Examining Legislation to Protect Consumers and Small Business Owners from Abusive Debt Collection Practices

October 5, 2022

Americans are struggling under very high debt burdens. An estimated one in every three adults with a credit report has a debt in collection. For the vast majority of these consumers, it not an unwillingness to pay their debts but a host of other factors that lead people into the hands of debt collectors, including…

2022 Consumer Protection Federal Priorities

October 5, 2022

Coalition Comments to CFPB Regarding Big Tech Payment Platforms

October 5, 2022

65 consumer, civil rights, faith, legal services and community groups submitted comments in response to the Consumer Financial Protection Bureau’s (CFPB) inquiry intocertain business practices of six large technology companies operating payments systems in the United States. In these comments, we would like to focus on consumer protections in those payment systems, and in particular…

Letter from CFPB Acting General Counsel Concerning Advisory Opinion on Earned Wage Access

October 5, 2022

Letter from Seth Frotman, Acting General Counsel at the Consumer Financial Protection Bureau to advocates concerning the Bureau’s advisory opinion on earned wage access.

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