Comment Letters

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.

October 30, 2017 | Filed under: Forced Arbitration

H.R. 2936, the poorly named “Resilient Federal Forest Act of 2017,” not only fails to improve the quality of public forests by promoting potentially harmful and destructive logging projects, but tramples on access to justice principles by stifling citizens’ ability to seek redress through our courts.

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 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 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. 

October 4, 2017 | Filed under: Credit Reporting

NACA submitted a letter to the U.S. House Financial Services Committee on the Equifax cybersecurity breach. "We urge the Committee to assert its intention to protect the tens of millions of impacted consumers across the country by supporting effective policies that: protect their personal information; restore and preserve their legal rights – such as the Consumer Financial Protection Bureau’s arbitration rule; and afford them meaningful remedies to make them whole when they are wronged."

October 3, 2017 | Filed under: Credit Reporting | Tagged with: CFPB, forced arbitration

NACA submitted a letter to the U.S. Senate Banking Committee to share its views for the Oct. 4 hearing on the Equifax cybersecurity breach. The Equifax breach is an object lesson on the consequences of a powerful entity that lacks adequate controls and incentive to act responsibly and in good faith in the marketplace. We urge the Committee to assert its intention to protect the tens of millions of impacted consumers across the country by supporting effective policies that: protect their personal information; restore and preserve their legal rights – such as the Consumer Financial Protection Bureau’s arbitration rule; and afford them meaningful remedies to make them whole when they are wronged.

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