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Consumer - Comments

Empire Justice Comments to CFPB Concerning Small Business Lenders in Rochester, NY
While the public CRA lending data adds to our understanding of the CRA performance by banks in their communities, compared to the publicly available HMDA data, the current formulation of the data has severe limitations. Read More

Empire Jusitce Comments on Protecting the Mortgage Insurance Fund
Empire Justice Center's comments focus on how HUD’s current foreclosure alternatives program for FHA-insured loans avoids unnecessary payment of insurance claims, and thus protects the mortgage insurance fund (Fund) and our communities. Read More

Joint Comments on Sterling Bancorp's Acquisition of Astoria Financial
We joined with other advocacy organizations representing Long Island to submit comments on Sterling Bancorp’s Proposed Acquisition of Astoria Financial Corporation. Read More

Empire Justice Comments to DFS on Vacant and Abandoned Properties
The proposed regulations for vacant and abandoned properties are quite comprehensive and thoughtfully address most of what needs to be included in the final regulations. Read More

Empire Justice Center Comments on People's United Financial Bank Merger
We urge the Federal Reserve Bank of New York and the Office of the Comptroller of the Currency (OCC) to only approve this merger after People’s United creates a robust community benefits plan in conjunction with community advocates in the bank’s footprint that addresses the forward-looking goals and priorities of their expanding institution. Read More

Empire Justice Center Comments to CFPB on High Cost Installment Loans
If there is an unwillingness to ban high-cost payday lending outright on the federal level, then we call on the CFPB to act with great care to ensure that the rules only have the effect of regulating payday lending where it is legal, and not the unintended effect of opening the door to payday ending in states where it is illegal. Read More

Empire Justice Comments on Proposed Federal Student Loan Regulations
After the closing of Everest we were inundated with calls for help from former students who were struggling to navigate the student loan discharge process. We found ourselves immersed in learning all we could about this process, and were shocked to find how challenging it was to navigate for a lay person. Read More

GRCRC Comments on JPMC 2011-2013 CRA Performance in Rochester
GRCRC about the Office of the Comptroller of the Currency'd examination of JPMorgan Chase. Read More

Joint Comments on Rural Mortgage Lending Exceptions
Empire Justice Center co-authors comments to the Consumer Financial Protection Bureau on interim rules that would exempt some lenders from many consumer protection rules. It's estimated that, if these rules go into effect without change, 6,000 lenders will be able to make 1.1 million loans under much weaker consumer protections. Read More

Empire Justice Comments on Key Bank - First Niagara Merger
Empire Justice comments on the proposed acquisition of First Niagara Financial Group, Inc. by KeyCorp. Read More

Empire Justice Comments on Consumer Complaint Narratives and Data Normalization
Empire Justice Center comments on the addition of consumer complaint narratives to the CFPB public database and how it is operating in practice. Read More

Empire Justice Comments on Proposed Reforms Relating to Consumer Credit Collection Cases
Our comments in support of the Unified Court System proposed rules governing consumer credit collection cases and suggesting minor improvements to make them more effective. Read More

Empire Justice and other NYRL members applaud OCC and FDIC for their strong guidance on deposit advance products
More than 40 members of New Yorkers for Responsible Lending signed onto a joint comment letter applauding federal regulators for issuing strong guidance to curb deposit advance products and payday lending. Read More

Empire Justice Comments to Regulators: Make Needed Comprehensive Changes to CRA Rules
Empire Justice's response to proposed changes to the Interagency Question and Answer (Q&A) document. Read More

Concerns Over CFPB's Changes to Remittance Protections
National Consumer Law Center and Empire Justice Center, along with other consumer advocacy organizations and law professors, sent joint comments to the Consumer Financial Protection Bureau, expressing concerns over reduced protections for consumers sending remittances. Read More

Empire Justice and Organizations Want Consumers Protected When Shopping for a Mortgage
Empire Justice Center was one of several organizations that sent a letter to the Consumer Financial Protection Bureau last month urging the CFPB to strengthen its proposed regulations around mortgage pricing and real estate closings so that consumers are better informed. Read More

NYRL Members Oppose FHFA Proposal to Raise New York's Guarantee Fee
Empire Justice Center and Greater Rochester Community Reinvestment Coalition, along with other NYRL members, oppose Acting Director DeMarco's proposal to raise the Federal Housing Finance Agency's guarantee fee for New York and other judicial foreclosure states. Read More

Empire Justice Comments to the Consumer Financial Protection Bureau on Reverse Mortgages
Our experience with reverse mortgages provides a unique yet critical viewpoint in understanding how valuable reverse mortgages can be when used responsibly as a tool to prevent seniors from losing their homes to foreclosures in Upstate New York. Read More

Comments to CFPB on Inclusion of a Public Database in Complaint Process
Consumer and other groups applaud the Consumer Financial Protection Bureau for including a public database in the CFPB complaint process, with recommendations for strengthening it. Read More

Empire Justice Center & Other NYRL Members Want Consumer Bureau to Broadly Define Who They Regulate in Certain Markets
Thirty-two members of NYRL urge the CFPB to define larger participants as broadly and as flexibly as possible, to ensure that the Bureau has maximum ability to directly supervise a wide array of institutions. Read More

Empire Justice Center Comments on CFPB's Proposal to Survey Consumers
Rather than create a general survey, Empire Justice recommends that the Bureau identify one or two key issues of focus by utilizing research and data already available on consumer attitudes, understanding and behaviors about consumer finance issues. Read More

NYRL Members Urge NY Courts to Go Further to Protect Homeowners in Foreclosure
In their comments on the Office of Court Administration's (OCA) amendment addressing problems with the current foreclosure process, members of New Yorkers for Responsible Lending ask the OCA to take additional steps to give homeowners a fair chance in the foreclosure process. Read More

AFR Urges CFPB Scrutiny of Private Student Lenders
Americans for Financial Reform (AFR), of which Empire Justice Center is a member, submitted comments to the Consumer Financial Protection Bureau documenting concerns about the private student loan industry. Read More

Comments on the Dept. of Treasury’s Activities to Expand Access to Mainstream Financial Institutions
Treasury’s endeavors are critical in the current environment. The current economic crisis has strained the financial stability of many families and pushed them out of the middle class. Read More

Empire Justice Center signs on to NYRL Letter Supporting a Strong Ability-to-Repay Standard
Fifty New Yorkers for Responsible Lending members urge federal regulators to implement the strongest, most robust regulations possible to protect consumers from abusive loans. Read More

Empire Justice Letter to HUD on Proposed Rules on Credit Risk Retention
To address abuses in mortgage lending and to ensure safe, quality mortgages for consumers, the interests of consumers, originators, securitizers and investors must be better aligned than in the past. Requiring risk retention by securitizers is one of the ways Dodd-Frank increases this alignment and incents higher quality lending. Read More

GRCRC Asks Federal Regulators to Strengthen Mortgage Lending Data Regulations
To coordinate with hearings being held across the country, the Greater Rochester Community Reinvestment Coalition submitted comments to federal banking regulators asking them to expand the disclosure of mortgage lending data under HMDA. Read More

Empire Justice Comments on the Federal Reserve's Proposed Amendments to Regulation E
Financial institutions should provide consumers who do not affirmatively consent to the institution’s overdraft service for ATM withdrawals and one-time debit card transactions an account with the same terms, conditions and features, including interest rates paid and fees assessed, as it provides consumers who affirmatively consent to overdraft services. Read More

Empire Justice Comments on Republic Bancorp's Application for a Charter Conversion
Empire Justice Center requests that the Office of Thrift Supervision hold a formal, public meeting on Republic Bancorp’s (“Republic”) application for a charter conversion from a bank holding company to a savings and loan holding company. Read More

Empire Justice Comments on the Exempt Income Protection Act
The purpose of the bill is to close a loophole in New York’s debt collection law, which currently allows banks to restrain accounts containing income that is exempt from collection, including social security, disability benefits, public assistance, pensions, college tuition trusts, and veterans benefits. Read More

GRCRC Comments on KeyBank's 2008 CRA Exam
This comment letter will focus mainly on mortgage and small business lending with a small section on community development activities. Read More

Empire Justice Comments on Proposed Amendments to Regulation AA
Comment in support of the Federal Reserve Board of Governor’s proposed amendments to Regulation AA, which curbs unfair and deceptive credit card and overdraft practices. While Empire Justice supports many aspects of this rule, we feel there needs to be additional and stronger protections against these unfair and deceptive acts. Read More

Empire Justice Comments on Proposed Changes to the Real Estate Procedures Act
This letter commends HUD for its efforts to simplify and improve the process of obtaining mortgages and to reduce settlement costs to consumers through proposed changes to the Real Estate Procedures Act (RESPA), and offers suggestions to improve the proposed changes. Read More

GRCRC Comments on Bank of America's Application to Acquire Countrywide Financial Corp.
If the Federal Reserve attaches certain specific conditions to Bank of America’s acquisition of Countrywide Financial, as outlined in our testimony and detailed in this letter, the Greater Rochester Community Reinvestment Coalition would not oppose the acquisition. Read More

GRCRC Comments on Proposed Amendments to the Truth in Lending Act
The proposed Regulation Z changes would give consumers important added protections. It is our position, however, that the proposals should be strengthened to make sure that consumers are adequately protected from the abuses that have led to the current crisis in the subprime mortgage lending industry. Read More

Empire Justice Comments on the Implementation of the Truth in Lending Act
It is our position that the proposals should be strengthened to make sure that consumers are adequately protected from the abuses that have led to the current crisis in the subprime mortgage lending industry and to ensure compliance. Read More

Empire Justice Guidance on Marketing of Refund Anticipation Loans
Empire Justice urges the IRS to amend regulations and adopt a rule prohibiting paid tax preparers from sharing tax return information to make refund anticipation loans. Read More

National Consumer Law Center Comments on Proposed Interagency Guidance on Garnishment of Exempt Federal Benefit Funds
Comments of the National Consumer Law Center on behalf of its low-income clients. Read More