COMMENTSof theNational Consumer Law Center,
andConsumer Action,
Consumer Federation of America,
Consumers Union
Leadership Conference on Civil Rights,
National Association of ConsumerAdvocates,
National Fair Housing Alliance,
and the Empire Justice Center
to the Board of Governors of the Federal Reserve System[Docket No. R-1305] Regarding Proposed Regulations Relating to Unfair TradePractices In Connection with Mortgage Lending
1
The National Consumer Law Center, Inc.
(NCLC)
is a non-profit Massachusetts Corporation, foundedin 1969, specializing in low-income consumer issues, with an emphasis on consumer credit. On a dailybasis, NCLC provides legal and technical consulting and assistance on consumer law issues to legalservices, government, and private attorneys representing low-income consumers across the country. NCLCpublishes a series of sixteen practice treatises and annual supplements on consumer credit laws, including
Truth In Lending
, (
6
th ed. 200
7
) and
Cost of Credit: Regulation, Preemption, and Industry Abuses
(3d ed.2005) and
Foreclosures
(
2d
ed. 200
7
), as well as bimonthly newsletters on a range of topics related toconsumer credit issues and low-income consumers. NCLC attorneys have written and advocatedextensively on all aspects of consumer law affecting low-income people, conducted training for thousandsof legal services and private attorneys on the law and litigation strategies to deal predatory lending andother consumer law problems, and provided extensive oral and written testimony to numerousCongressional committees on these topics. NCLC’s attorneys have been closely involved with theenactment of the all federal laws affecting consumer credit since the 1970s, and regularly provide extensivecomments to the federal agencies on the regulations under these laws. These comments are filed on behalf of NCLC’s low-income clients and were written by Alys Cohen, Elizabeth Renuart, Margot Saunders, andDiane Thompson.
2
Consumer Action
(www.consumer-action.org) is a national non-profit education and advocacyorganization that has served consumers since 1971. Consumer Action (CA) serves consumers nationwideby advancing consumer rights in the fields of credit, banking, housing, privacy, insurance and utilities. CAoffers many free services to consumers and communities. Consumer Action develops free consumereducation modules and multi-lingual materials for its network of more than 10,000 community basedorganizations. The modules include brochures in Chinese, English, Korean, Spanish and Vietnamese.
3
Consumer Federation of America
(CFA) is a nonprofit association of some 300 national, state, and localpro-consumer organizations created in 1968 to represent the consumer interest through research, advocacy,and education. Among the reports issued by CFA concerning the current mortgage crisis are the following:
Exotic or Toxic? An Examination of the Non-Traditional Mortgage Products for Consumers and Lender
s
;
and
Subprime Locations: Patterns of Geographic Disparity in Subprime Lending.
4
Consumers Union
is a non-profit membership organization chartered in
1936 under the laws of the state of New York
to provide consumers with information, education and
counsel
about goods, services, health and personal finance, and to initiate and cooperate with individualand group efforts to maintain and enhance the quality of life for consumers. To maintain our independenceand impartiality, Consumers Union accepts no outside advertising, no free test samples, and has no agendaother than the interests of consumers. Consumers Union supports itself through the sale of our informationproducts and services, individual contributions, and a few noncommercial grants. Consumer Reports,Consumer Reports Online, and our health and financial newsletters, with more than 7.4 million paidsubscribers, regularly carry articles on health, product safety, financial services, marketplace economicsand legislative, judicial and regulatory actions which affect consumer welfare. Consumers Union joins inthese comments to strongly endorse these regulatory and policy recommendations. The facts and examplesdescribed in these comments are provided by other commentors.
5
The
Leadership Conference on Civil Rights
(LCCR) is the nation’s oldest, largest, and most diversecoalition of civil rights organizations. Founded in 1950 by Arnold Aronson, A. Philip Randolph, and Roy
i
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