Comment Letters

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.

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.

October 23, 2017 | Filed under: Other Areas of Interest | Tagged with: Regulatory Enforcement

NACA joins organizations in opposing H.R. 732, the so-called Stop Settlement Slush Funds Act of 2017 that would prohibit settlement agreements where the United States is a party from including certain “donations” to non-federal actors, primarily non-profits, educational, and community-based organizations. Settlements from federal enforcement actions can include payments to third parties to advance programs that assist with recovery, benefits, and relief for communities harmed by lawbreakers. H.R. 732 would cut off any payments to third parties other than individualized restitution and other forms of direct payment for “actual harm.” That restriction would handcuff federal enforcement officials by limiting the ability of federal enforcement officials to negotiate real relief for harms caused to the public by illegal conduct that is the subject of federal enforcement actions.

October 23, 2017 | Filed under: Other Areas of Interest | Tagged with: Access to justice, Regulations

The so-called “Sunshine for Regulations and Regulatory Decrees and Settlements Act of 2017” would undermine the enforcement of federal laws and impede the resolution of various consumer protection, anti-discrimination, environmental, and public health cases before our federal courts.

October 11, 2017 | Filed under: Other Areas of Interest | Tagged with: Banking, Regulations

NACA, organizations oppose H.R. 2706, the Financial Institution Customer Protection Act of 2017. The bill will hamper the efforts of banking regulators to advise financial institutions of warning signs that their customers are engaging in fraud, money laundering, or other illegal activity, putting consumers and financial institutions at risk of serious financial loss. The bill would also promote spurious litigation against regulators and financial institutions when an account is closed. 

September 27, 2017 | Filed under: Other Areas of Interest | Tagged with: Banking, Overdraft Fees

The Community Bank Advisory Council of the Consumer Financial Protection Bureau (bureau) should recommend meaningful solutions to address the size and number of overdraft fees that institutions mount on their customers, said five public interest organizations (Americans for Financial Reform, Center for Responsible Lending, Public Citizen, National Consumer Law Center, and NACA) in a letter to the bureau.

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 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.