Comment Letters

January 2, 2018 | Filed under: Forced Arbitration

NACA commends Rep. Cheri Bustos' (IL) introduction of H.R. 4734, the Ending Forced Arbitration of Sexual Harassment Act. By making forced arbitration clauses invalid and unenforceable for claims of sexual harassment and other forms of sex discrimination as defined under Title VII of the Civil Rights Act of 1964, the legislation would ensure that workers can go to court to enforce critical protections and help them to seek justice for related harm. The proposal would be a positive step forward in the effort to eliminate forced arbitration altogether and restore individuals’ legal rights in consumer and workplace disputes.

*Revised January 3, 2018

December 18, 2017 | Filed under: Other Areas of Interest | Tagged with: CFPB, Insurance

Groups oppose HR 3746, the Business of Insurance Regulatory Reform Act of 2017 which would limit the CFPB’s authority to enforce federal consumer financial protection laws against entities that are regulated by a state insurance regulator to the extent such person is engaged in the business of insurance. The bill could have wide-ranging impacts that infringe on the CFPB’s core authority to address problems with consumer financial products and services.

December 12, 2017 | Filed under: Other Areas of Interest | Tagged with: consumer protection, net neutrality

NACA joined a broad coalition letter to Congress opposing the Federal Communications Commission (FCC)'s order that would reverse its own net neutrality rule issued in 2016. The net neutrality rule was based on the principle that all data on the internet should be treated equally, and that internet service providers (ISPs) should not discriminate or provide preference to any data, regardless of its source, content, or destination.

December 4, 2017 | Filed under: Mortgage, Real Estate & Housing

NACA  submitted a letter to the U.S. Senate Banking Committee to urge opposition to S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act.” The financial marketplace does not need this so-called “regulatory relief” legislation. The bill overall would weaken protections for homeowners and expand the scope of risky activity for big banks and lenders to engage in at the expense of American consumers and the economy.

November 27, 2017 | Filed under: Telephone Consumer Protection Act

NACA joined National Consumer Law Center, Consumer Action, Consumer Federation of America, Public Citizen, and Public Knowledge to oppose a petition filed by ContextMedia, Inc. d/b/a Outcome Health to the Federal Communications Commission, seeking relief from liability under the Telephone Consumer Protection Act.


November 19, 2017 | Filed under: Student Loans

NACA joins organizations in comments to the Department of Education opposing further delay implementation of the 2016 final regulations on borrower defense, closed school discharge, false certification discharge, financial responsibility, and forced arbitration by schools in the Direct Loan program .

November 13, 2017 | Filed under: Mortgage, Real Estate & Housing

NACA joins with Americans for Financial Reform coalition to oppose H.R. 1699, the so-called Preserving Access to Manufactured Housing Act of 2017. This bill poses significant dangers for consumers and homebuyers by exempting manufactured housing lenders from requirements that protect borrowers against inappropriately high-cost loans.

November 13, 2017 | Filed under: Other Areas of Interest | Tagged with: Predatory Lending

NACA joined 150+ national and state organizations to strongly oppose H.R. 3299 (McHenry) and S. 1642 (Warner), the Protecting Consumers’ Access to Credit Act of 2017. The primary impact of this bill will be enabling nonbank lenders to make high-cost loans that exceed state interest rate limits by using a bank to originate the loan. The bill poses a serious risk of enabling predatory lending and unsafe lending practices. Unaffordable loans have devastating consequences for borrowers—trapping them in a cycle of unaffordable payments and leading to harms such as greater delinquency on other bills.

November 7, 2017 | Filed under: Forced Arbitration

In a letter to the Senate Judiciary Committee, NACA wrote: "Access to justice is a fundamental right of the American people and small businesses. Yet overwhelmingly, harmed consumers and small businesses face impenetrable obstacles when they seek to go to court to obtain remedies. The Committee should reject any proposals that would further delay and deny ordinary people and small businesses of the right to use the public court system or that would interfere with the ability of judges and juries to do their jobs. Instead, the Committee should examine ways to restore meaningful remedies and access to court for individuals and small merchants."

November 6, 2017 | Filed under: Telephone Consumer Protection Act

NACA joins comments to the Federal Communications Commission to oppose requested exemptions from requirements for consent to direct automated calls and texts to the members of credit unions, made by the Credit Union National Association (CUNA). Neither requested exemption is legally permitted under the Telephone Consumer Protection Act (TCPA), and allowing either exemption would seriously and significantly add to the number of unwanted robocalls now made by financial institutions.