Comment Letters

April 24, 2017 | Filed under: Student Loans | Tagged with: CFPB

NACA joins Americans for Financial Reform (“AFR”) in comments on the Consumer Financial Protection Bureau’s Request for Comment on Student Loan Servicing Market Monitoring. We support the Bureau’s proposed student loan servicing data collection initiative and believe that compiling such metrics and borrower outcomes would benefit market participants, federal and state agencies, policymakers, and borrowers. Obtaining a clearervview of the student loan market overall will help inform all market participants on how best to serve student loan borrowers.

April 18, 2017 | Filed under: Other Areas of Interest | Tagged with: CFPB, Prepaid Cards

The undersigned 235 consumer, civil rights, labor and small business organizations urged opposition H.J. Resolutions 73 & 62, which would reject the Consumer Financial Protection Bureau’s prepaid card protection rule. The resolution would block basic fee transparency and fee disclosure protections set to go into effect on prepaid cards, including payday lender prepaid cards and low-wage employer payroll cards such as those offered by Georgia-based NetSpend.

March 22, 2017 | Filed under: Student Loans

NACA joins organizations conveying strong support for the continued implementation and enforcement of important Education Department accountability provisions designed to protect students and taxpayers from unmanageable student debt and waste, fraud and abuse in higher education. In particular, we oppose all actions to delay, weaken, or repeal the gainful employment, incentive compensation, or recent “borrower defense to repayment” and college accountability regulations.

March 17, 2017 | Filed under: Debt Collection | Tagged with: CFPB, LEP

Organizations submitted a letter in response to the CFPB’s Small Business Regulatory Enforcement Fairness Act (SBREFA) review of proposed regulations under the Fair Debt Collection Practices Act (FDCPA). Specifically, the letter addresses the Bureau’s proposal related to increasing access to the FDCPA’s protections for Limited English Proficient (LEP) consumers. We applaud the Bureau for raising the issue of language access in the context of debt collection and for seeking feedback on this important issue.

March 8, 2017 | Filed under: Class Actions

NACA urges House members to vote NO on H.R. 985. First, House supporters of H.R. 985 have failed to explain why this bill is necessary. The House Judiciary Committee literally refused to examine the policy considerations, reporting H.R. 985 without even a hearing. Second, the legislation’s extreme proposals would disrupt class action proceedings with onerous and unnecessary requirements, cutting off access to justice for millions of Americans injured by corporations that break the law. Meanwhile, corporations would be free to disregard state and federal protections for consumers and workers without fear of being held accountable.

March 7, 2017 | Filed under: Class Actions

H.R. 985 IS AN UNWARRANTED ATTACK ON AMERICANS’ ACCESS TO COURT - The bill’s provisions to delay and deny participation in class actions would harm the public interest. It would foster a prolonged and protracted process for class actions that would unduly delay or deny justice for ordinary Americans, without any countervailing benefit. Ultimately, the proposal would wipe out consumer, investor and worker claims regardless of the extent of harm caused by bad actors.

February 15, 2017 | Filed under: Class Actions

NACA writes House Judiciary Committee to urge opposition to H.R. 985, the “Fairness in Class Action Litigation Act of 2017.” The legislation’s extreme proposals would disrupt class action proceedings with onerous and unnecessary requirements, cutting off access to justice for millions of Americans injured by corporations that break the law.  Meanwhile, corporations would be free to disregard state and federal protections for consumers and workers without fear of being held accountable. 

February 14, 2017 | Filed under: Class Actions

NACA joins other organizations in a letter to the U.S. House Judiciary Committee to strongly oppose the Fairness in Class Action Litigation Act of 2017. If this bill were enacted into law, it would obliterate class actions in America. It was introduced less than a week ago. The fact that the Committee would even consider such sweeping, reckless legislation without holding a single hearing is an outrage."

February 6, 2017 | Filed under: Forced Arbitration

Public interest organizations sent a letter urging support of H.R. 585, which would amend the Securities Exchange Act of 1934 to prohibit mandatory pre-dispute arbitration (or forced arbitration) clauses in contracts that investors often must enter into as a condition for receiving services from broker-dealers or investment advisers. H.R. 585, sponsored by Rep. Keith Ellison and 11 original cosponsors, will restore investors’ ability to choose how to resolve disputes after they arise, whether in court, arbitration or other dispute resolution proceedings. 

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