Comment Letters

September 3, 2020 | Filed under: Small Dollar Loans | Tagged with: OCC, Predatory Lending, Preemption

National consumer advocacy organizations strongly oppose the Office of the Comptroller of the Currency proposal that would preempt the authority of states and courts to look beyond contrivances to the truth to prevent evasions of state usury laws. The proposal would eliminate state interest rate limits for nonbank predatory lenders in every state as long as a bank’s name is in the fine print.

September 3, 2020 | Filed under: Small Dollar Loans | Tagged with: CLASS Network, OCC, Predatory Lending, Preemption

Members of the Consumer Law Advocates, Students, and Scholars (CLASS) network submitted comments to the Office of the Comptroller of the Currency in response to its proposed rule that would allow nonbank lenders to avoid state law that currently protects many of these consumers. The rule will give new life to the “rent-a-charter” schemes that preyed on consumers in the early 2000s – schemes the OCC itself acted to eliminate.

**The C.L.A.S.S. Network is a joint project of the National Association of Consumer Advocates, the UC Berkeley Center for Consumer Law & Economic Justice and Berkeley Law's student-run Consumer Advocacy & Protection Society (CAPS) to establish and expand a nationwide network of law school student organizations dedicated to the promotion of consumer law. 

September 1, 2020 | Filed under: Other Areas of Interest | Tagged with: Congress, Legislation

NACA joined a letter in support of the bipartisan Payment Choice Act which would preserve the right of consumers to pay with cash at retail locations. Cashless businesses unfairly disadvantage underbanked communities.

August 17, 2020 | Filed under: Debt Collection | Tagged with: Debt Collection

NACA and 18 non-profit advocacy organizations sent a letter to the DC Council in suport of the Debt Buying Limitation Amendment Act of 2019 in anticipation of a wave new debt collection activity after emergency COVID-19 protections expire.

August 12, 2020 | Filed under: Other Areas of Interest | Tagged with: Congress, COVID-19

NACA and 91 consumer, civil rights, community, labor, housing, and other public interest organizations sent a letter to Congress urging it to adopt broad consumer protection measures in the next COVID-19 relief package.

August 11, 2020 | Filed under: Other Areas of Interest | Tagged with: CFPB, consumer complaints

NACA joined consumer, civil rights, community, housing, and privacy organizations on a letter to the Consumer Financial Protection Bureau urging the agency to reconsider changes its made to the Consumer Complaint database. The changes make it overly difficult for the public to navigate the database and to view consumer complaint narratives.

August 4, 2020 | Filed under: Debt Collection | Tagged with: CFPB

"Disclosures that the Bureau is currently proposing, which are meant to make consumers aware of their rights concerning old, expired debt, are inadequate to combat the pervasive harms caused by collectors’ deceptive practices in this area."

July 29, 2020 | Filed under: Other Areas of Interest | Tagged with: CFPB, COVID-19

NACA sends letter to House Financial Services Committee in anticipation of a hearing on the Consumer Financial Protection Bureau's semi-annual report.

July 28, 2020 | Filed under: Other Areas of Interest | Tagged with: CFPB, Congress, COVID-19

In anticipation of the Senate Banking Committee's hearing on CFPB's Semi-Annual Report, NACA inks letter to the committee: "the CFPB’s lackluster performance over the past year, particularly in light of the extraordinary health and economic crisis this country now faces, puts the U.S. financial marketplace and the millions of consumers who participate in it at risk."

July 22, 2020 | Filed under: Student Loans | Tagged with: COVID-19, student protection

NACA joined a letter to congressional leaders urging them to strengthen oversight of COVID-19 related aid to higher education institutions, particularly for-profit colleges, in any future relief packages.

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