Comment Letters

September 20, 2017 | Filed under: Small Dollar Loans | Tagged with: Predatory Lending

NACA joins organizations in supporting the Senate and House companion bills, S. 1659/H.R. 3760, the “Protecting Consumers from Unreasonable Credit Rates Act,” sponsored by Senator Richard Durbin, Senator Jeff Merkley, Representative Matt Cartwright, and Representative Steve Cohen. The Senate and House bills would extend to all consumers a 36 percent usury APR cap. A fair rate cap will protect consumers by curbing abuses in the high-cost small dollar loan market, while permitting responsible lending on reasonable terms to continue. A strong rate cap also has strong public support, with a large majority of the public consistently supporting interest rate caps on payday, car title, and other high-cost loans.1

September 19, 2017 | Filed under: Credit Reporting

NACA joins oranizations to strongly support The Equal Employment for All Act (S.1819), introduced by Senator Elizabeth Warren. The bill would eliminate an unfair and discriminatory barrier to economic mobility and security for many Americans by prohibiting the use of personal credit history in employment.

September 18, 2017 | Filed under: Other Areas of Interest | Tagged with: FTC

NACA, consumer organizations expressed strong opposition to an amendment offered by Congressman Moolenaar that was included in the FY18 Financial Services and General Government Appropriations bill.  This amendment, based on the “Anti-Pyramid Scheme Promotion Act of 2016,”ii would rob the Federal Trade Commission (“FTC”) of its ability to protect consumers from all but the most egregiously fraudulent pyramid schemes.

September 13, 2017 | Filed under: Other Areas of Interest | Tagged with: FCC

NACA joins comments to the Federal Communications Commission (FCC)  re:  its examination of rulemaking to ease the problem of “slamming,” in which a customer’s long-distance carrier is changed without his or her knowledge, as well as the problem of “cramming”—when a third party enters unauthorized charges into a consumer’s phone bill. Though the FCC has examined cramming and slamming several times over the last ten years, and has extended important protections to consumers—for example, requiring carriers to list third-party charges separately on bills, and to inform customers if they offer a service to block third-party charges, regulatory gaps persist.

September 13, 2017 | Filed under: Telephone Consumer Protection Act | Tagged with: FCC

Consumers Union, Consumer Action, Consumer Federation of America, National Association of Consumer Advocates, National Consumer Law Center on behalf of its low-income clients, National Consumers League, Public Citizen, and Public Knowledge thanked the Federal Communications Commission (FCC) for its work to encourage the development of a caller ID authentication system to address fraudulent call spoofing, and are encouraged by the support for the project revealed in the submitted comments. Fraudulently spoofed calls evade call-blocking mechanisms, threaten consumers with scams and fraud, and disturb their privacy. Thus, we reiterate our call for the FCC to take rapid action, to require full participation by providers, and to take the lead in establishing effective standards for consumer protection.

September 6, 2017 | Filed under: Credit Reporting | Tagged with: Class Actions

Compelling case stories show credit reporting agencies whose conduct was so detrimental that individual consumers were unable to get serious errors in their credit reports or background checks fixed until they sued in court, and examples of consumers who banded together in class actions to seek accountability for violations of their rights under the Fair Credit Reporting Act. Under H.R. 2359, “FCRA Liability Harmonization Act,” these consumers would have been denied the ability to seek adequate remedies against bad actors.


Read the letter from public interest organizations.

Read NACA's letter to the Committee. 

Read testimony of hearing witness Chi Chi Wu.

September 6, 2017 | Filed under: Credit Reporting | Tagged with: Class Actions

H.R. 2359, the “FCRA Liability Harmonization Act,” would deprive victims of credit reporting abuses of deserved compensation for their losses and would disrupt the marketplace by diminishing the justice system as a key tool to deter systemic and abusive conduct in the vast and complex credit reporting and information system.

September 6, 2017 | Filed under: Credit Reporting | Tagged with: Class Actions

Public interest organizations wrote a letter to U.S. House Financial Services Committee to urge opposition to H.R. 2359, titled the “FCRA Liability Harmonization Act.” The legislation would restrict remedies for American consumers whose credit reports and background check reports were recklessly distorted and who suffered serious consequences as a result, including losing their ability to access credit such as a mortgage, a car loan, rental housing, or employment. Limiting damages in Fair Credit Reporting Act (FCRA) legal actions, as this bill proposes, would embolden credit reporting and background check agencies to disregard federal protections meant to ensure accurate reporting of credit records and other consumer reports. The bill would allow bad actors in the credit reporting industry to wrongfully label consumers as deadbeats, terrorists, and criminals without fear of meaningful consequences. It also would have a deleterious effect on the marketplace due to the spread of defective data and information on millions of consumers and workers that almost inevitably would result.

The organizations also submitted a fact sheet demonstrating real and consequential harm to consumers.

September 5, 2017 | Filed under: Other Areas of Interest | Tagged with: budget

NACA joins letter to oppose any House FY 2018 appropriations bills or packages which include harmful policy riders. Appropriations bills continue to be misused to undermine essential safeguards through poison pill “policy riders” – provisions that address extraneous and unpopular policy issues. Slipping unrelated and damaging issues into must-pass appropriations bills as a means to win approval is a dangerous strategy for the public.

August 24, 2017 | Filed under: Mortgage, Real Estate & Housing

Request for publication of the opinion issued in Mackovaska v. Bank of America.