Testimony and Comments

Legislators and policymakers around the country rely on NCLC's legal and policy analysts for their expert testimony, empirical research, and analysis to help predict and shape the efffect of proposed statutes and policies on low-income consumers. On this page you will find statements from NCLC experts on issues involving consumer fraud, debt collection, consumer finance, energy assistance programs, predatory lending, and sustainable home ownership programs.

Credit Cards || Predatory Mortgage Lending || RESPA || Refund Anticipation Loans || Student Loans || Energy and Utility || Telecommunications || Fair Credit Reporting || Debt Collection || Credit Counseling || Bounce Loans || FCRA Amendments || Other Consumer Protection Issues

Credit Cards

The Federal Reserve Board has asked the public for comments about credit card practices. The FRB writes the rules for the Truth in Lending Act, which regulates credit card disclosures and protections. Tell the FRB what you think by MARCH 28, 2005.

• Sample Letter to Federal Reserve Board on Credit Card Practices (March 2005) >>>
• Comments of the National Consumer Law Center and Others >>>
  Appendices to Comments >>>

Predatory Mortgage Lending

• Letter to Senate Banking Committee on Katrina victims and financial services (September 23, 2005) >>>
• Letter to House Financial Services Committee on Katrina victims and financial services (September 23, 2005) >>>
• Comments to the Massachusetts Division of Banks regarding 209 CMR §§ 32.32, 34, 40: Predatory Home Loan Practices (March 16, 2005) >>>
• Comments of the National Consumer Law Center to Office of Comptroller of the Currency Rules, Policies, and Procedures for Corporate Activities - Annual Report on Operating Subsidiaries (April 2004) >>>
• Testimony before the Subcommittee on Housing and Community Opportunity and Subcommittee on Financial Institutions and Consumer Credit regarding Protecting Homeowners: Preventing Abusive Lending While Preserving Access to Credit (November 5, 2003) >>>
• Comments to the Office of Comptroller of the Currency regarding Banking Activities and Operations; Real Estate Lending and Appraisals, Docket No. 03-16 (October 2003) >>>
• Comments of NCLC, CFA and NACA regarding Community Reinvestment Act Regulations (April 2003) >>>
• Testimony before the Banking, Housing and Urban Affairs Committee regarding the Impact of the Proposed RESPA Rule on Small Businesses and Consumers (April 2003) >>>
• Comments to the Office of Comptroller of the Currency - Notice of Request for Preemption Determination (March 2003) >>>
• Comments to the Office of Thrift Supervision regarding the Proposed Amendment to Regulations Issued Pursuant to the Alternative Mortgage Transaction Parity Act on Prepayment Penalties (June 24, 2002) >>>
• Testimony regarding the Increase in Predatory Lending and Appropriate Remedial Actions (July 2001) >>>
• Comments to the Federal Reserve Board regarding Proposed Changes to HOEPA  (March 9, 2001) >>>
• Comments to the FDIC on Predatory Mortgages  (January 31, 2001) >>>
• Testimony re Amendments to 209 CMR §§ 32.32, 42, 40 High Cost Mortgage Loan Provisions in Massachusetts (October 3, 2000) >>>
• Comments to the Federal Reserve Board on Its Authority to Expand Protections Against Predatory Lending  (August 4, 2000) >>>
• Comments Regarding the Advance Notice of Proposed Rulemaking (July 5, 2000) >>>
• Testimony Regarding the Increase in Predatory Lending and Appropriate Remedial Actions (May 24, 2000) >>>
• NCLC's Comments on HUD's Regulation of Freddie Mac and Fannie Mae  (May 8, 2000) >>>
• Press Release: Common Mortgage Lending Practice Found to Violate Consumer Protections (December 1999)
• Testimony to the Senate Committee on Banking, Housing and Urban Affairs regarding the Federal Housing Administration Loan Program (June 1998) >>>
• Comments to Senate Special Committee on Aging to be included in the record of the hearing - Equity Predators: Stripping, Flipping, and Packing Their Way to Profit (April 16, 1998) >>>
• Testimony regarding H.R.607 Homeowners Insurance Protection Act (March 1997) >>>
• Comments on Truth in Lending - Regulation Z; Docket No. R-1005 >>>

• Letter to Senators: Do Not Impose Stays on Class Actions Involving Fees Paid By Lenders to Mortgage Brokers

RESPA (Real Estate Settlement Procedures Act)

• Testimony before the Financial Services Committee Subcommittee on Housing and Community Opportunity regarding Simplifying the Home Buying Process: HUD’s Proposal to Reform RESPA (February 2003) >>>
• Comments on RESPA Proposed Rule to Simplify and Improve the Process of Obtaining Mortgages to Reduce Settlement Costs to Consumers (November 2002) >>>
• Testimony regarding Rewrite of Truth in Lending Act and Real Estate Settlement Procedures Act (September 1998) >>>
• Testimony regarding Financial Institution Regulatory Streamlining Act of 1998 (July 1998) >>>
• Testimony regarding Financial Regulatory Relief and Economic Efficiency Act of 1997 (March 1998) >>>
• Letter to a Member of the VA-HUD Appropriation Subcommittee regarding Mr. Neumann's proposed amendment to RESPA (March 1998)
• Testimony regarding Rewrite of RESPA and Proposed Moratoria on HUD Employee Compensation Rule and Class Action Suits Challenging Lender Paid Mortgage Broker Fees (July 1997) >>>

Refund Anticipation Loan

• Comments to U.S. Treasury Department regarding Subprime Mortgage Marketing through IRS Free File (March 25, 2003) >>>
• Comments to IRS regarding Electronic Tax Preparation and Filing; Intent to Enter Agreement (September 4, 2002) >>>

Student Loans

• Testimony before the Government Reform Committee Subcommittee on Government Efficiency and Financial Management regarding “The Debt Collection Improvement Act" (June 17, 2003) >>>
  Supplemental Testimony regarding “The Debt Collection Improvement Act" (July 1, 2003) >>>
• Comments to the Department of Education on Proposed Institutional Eligibility Regulations (October 2002) >>>
• Comments to the Department of Education regardig Proposed Administrative Wage Garnishment Regulations (June 11, 2002) >>>
• Comments regarding U.S. Education Department's Notice of Proposed Rulemaking (Disability Discharges) (August 3, 2000) >>>

Energy and Utility

• Testimony of the National Consumer Law Center on Behalf of Our Low-Income Clients Before the House Subcommittee on Labor, Health and Human Services, Education U.S. House Committee on Appropriations regarding FY 2006 Appropriations for the Low Income Home Energy Assistance Program (LIHEAP) (April 2005) >>>
• Testimony before the House Subcommittee on Labor, Health and Human Services, Education U.S. House Committee on Appropriations - FY 2005 Appropriations for the Low Income Home Energy Assistance Program (LIHEAP) (April 30, 2004) >>>
• Initial Brief of the Massachusetts Community Action Program Directors Association regarding KeySpan's Proposed Low-income Arrearage Management Program ("On Track") (August 29, 2003) >>>
• NCLC's Testimony submitted to the United States House Of Representatives Committee on Appropriations Subcommittee on Labor, Health And Human Services and Education regarding FY 2004 Appropriations for the Low Income Home Energy Assistance Program (LIHEAP) (May 23, 2003) >>>
• NCLC's Initial Testimony of Proposed Service Quality Rules for California Telecommunications Carriers (March 31, 2003) >>>
• Request for Comments on Cancellation or Termination of Utility Services Exception to the Electronic Signatures in Global and National Commerce Act (March 31, 2003) >>>
• Proposed Pricing Policy for Efficient Operation and Expansion of the Transmission Grid: Comments of WUTC at al Recommending That The Policy Statement be Tailored to Regional Circumstances and Limited to Actions that Yield Consumer Benefits in Excess of Consumer Costs (March 13, 2003) >>>
• Commonwealth of Massachusetts, Department of Telecommunications And Energy, Increasing The Penetration Rate For Discounted Electric, Gas And Telephone Service, DTE 01-106, Additional Comments (November 14, 2002) >>>
• Commonwealth of Massachusetts, Department of Telecommunications And Energy, Increasing The Penetration Rate For Discounted Electric, Gas And Telephone Service, DTE 01-106, Comments (January 31, 2002) and Reply Comments (March 7, 2002)
• Testimony Before Joint Committee on Commerce and Labor of the Massachusetts General Court Regarding S. 141 (May 9, 2001) >>>
• Testimony Before the Senate Committee on Health, Education, Labor and Pension Regarding High Fuel Costs and Low-Income Families (October 3, 2000) >>>

• Testimony on FY 2001 Appropriations for the Low Income Home Energy Assistance Program (LIHEAP) (April 24, 2000) >>>
• Mass. Department of Public Utilities Electric Industry Restructuring Rulemaking DPU 98-100 Low-income Comments (May 27, 1996) >>>
• Testimony before the Subcommittee on Labor, Health and Human Service, and Education, and Related Agencies Committee on Appropriations United States Senate regarding Fiscal Year 1997 Appropriations for the Low-Income Home Energy Assistance Program (LIHEAP) (May 6, 1996) >>>
• NCLC's Senate Testimony in Support of LIHEAP (Low Income Home Energy Assistance Program) >>>

Telecommunication

• Joint Comments of the National Consumer Law Center, The Utility Reform Network and Consumers Union regarding the Telecommunications Consumers Bill of Rights, filed with the California Public Utilities Commission (August 26, 2003)
  Appendix A - Consumer Groups’ Revised Conclusions of Law and Interim Order
  Appendix B - Consumer Group Proposed Edits
• Comments on Proposed Rules for the Lifeline and Link-Up Programs in FCC Docket WC 03-109 (August 18, 2003) >>>
• NCLC's Initial Testimony of Proposed Service Quality Rules for California Telecommunications Carriers (March 31,2003) >>>
• Comments of NCLC, TURN and UCAN in the Telecommunications Consumers Bill of Rights proceeding before the California Public Utilities Commission (October 31, 2002) >>>
• Before the Federal Trade Commission in the matter of Telemarketing Rulemaking - Comment FTC File No. R411001 (April 15, 2002) >>>
• Commonwealth Of Massachusetts, Department Of Telecommunications And Energy, Increasing The Penetration Rate For Discounted Electric, Gas And Telephone Service, DTE 01-106, Comments, January 31, 2002 and Reply Comments (March 7, 2002) >>>
• NCLC's Comments before The Federal Communications Commission, Joint Board On Universal Service, CC Docket No. 96-45/FCC 01J-2, Comments (December 28, 2001)
  Penetration Rates for Lifeline Services by State

Fair Credit Reporting

• Testimony to the Board of Governors of the Federal Reserve System regarding the Request for Information for the Study on Investigations of Disputed Consumer Information Reported to Consumer Reporting Agencies Docket No. OP-1209 (September 17, 2004) >>>
• Testimony regarding the Model Notice of Furnishing Negative Information (May 2004) >>>
• Testimony before the Committee on Financial Services Subcommittee on Finanacial Institutions and Consumer Credit regarding the Fair Credit Reporting Act: How it Functions for Consumers and the Economy (June 2003) >>>
• Testimony before the Committee on Financial Services Subcommittee on Financial Institutions & Consumer Credit regarding H.R. 1701 the Consumer Credit Protection Act: Why H.R. 1701, The Consumer Credit Protection Act, is Anti-Consumer? (July 2001) >>>
• Testimony to House Banking Committee on Employer Investigations of Employee Misconduct under the Fair Credit Reporting Act (May 2000) >>>

Debt Collection

• Letter to Congress: Check Diversion Companies Should Remain Covered by the Fair Debt Collection Practices Act (April 2004) >>>
• Testimony regarding the Debt Collection Improvement Act (June 2003) >>>
  Supplemental Testimony regarding the Debt Collection Improvement Act (July 2003) >>>
• Testimony before the Ways and Means Committee Subcommittee on Oversight regarding the Use of Private Collection Agencies to Improve IRS Debt Collection (May 2003) >>>
• Letter to Senate on Proposed Amendments to the FDCPA (June 2000) >>>
• Letter to the National Association of Insurance Commissioners regarding NAIC Creditor-Placed Insurance Model Act (September 1996) >>>

Credit Counseling

• Testimony before the Subcommittee on Housing and Community Opportunity regarding Successful Homeownership and Renting through Housing Counseling (March 2004) >>>
• Testimony before the House Ways and Means Committee Subcommittee on Oversight regarding Non-Profit Credit Counseling Organizations (November 2003) >>>

Bounce Loans

• Press Release: Federal Reserve Bank Regulation Fails to Protect Consumers From Predatory “Overdraft Bounce Loan” Products
• Comments to FRB and Banking Regulators Concerning Bounce Loans (August 8, 2004)

Press Release: FRB Overdraft Loan Proposals Fail to Protect Consumers
Comments regarding FRB Proposal to Regulate Bounce Loans under Truth in Savings and Proposed Interagency Guidance
Selected Appendices to Comments

• Press Release: Consumer Groups Urge Federal Reserve Board to Stop Abusive Bank Overdraft Charges (January 2003)

Comments regarding Open End Credit and HOEPA Triggers and Solicitation for Comments on Bounce Protection Products
Appendix: Bounce Protection: How Banks Turn Rubber into Gold by Enticing Consumers to Write Bad Checks
An Examination of Bounce Protection Plans

• Full text of legislation (PDF)
• NCLC analysis & comments
• Consumer Union analysis & More

Other Consumer Protection Issues

• Letter to Senate Banking Committee Regarding Bernanke Nomination (October 24, 2005) >>>
• Comments of the National Consumer Law Center, Consumers Union, and the Consumer Federation of America regarding the proposed amendments to Reg E on ATM disclosures (October 5, 2005) >>>
• Testimony before the Senate Committee on Banking, Housing and Urban Affairs regarding Current Proposals Considered for Regulatory Relief Legislation (June 21, 2005) >>>
• Comments of the National Consumer Law Center on behalf of its Low Income Clients regarding Petition for Rulemaking to Preempt Certain State Laws Federal Deposit Insurance Corporation (May 16, 2005) >>>
• Testimony regarding “Helping Consumers Obtain the Credit They Deserve” to the Subcommittee on Financial Institutions and Consumer Credit (May 12, 2005) >>>
• Comments of the National Consumer Law Center and Consumer Federation of America, Consumers Union, National Association of Consumer Advocates and U.S. Public Interest Research Groups: Docket No. R-1226 Proposed Amendment to Regulation J and Regulation CC Regarding Remotely Created Checks (May 11, 2005) >>>
• Testimony before the House Committee on Veterans’ Affairs regarding Protecting the Rights of Those Who Protects Us: Public Sector Compliance with the Uniformed Services Employment and Reemployment Rights Act (USERRA) and Improvements to the Servicemembers Civil Relief Act (SCRA) (June 23, 2004) >>>
• Testimony to the Senate Committee on Banking, Housing and Urban Affairs regarding All Current Proposals for Legislation on Financial Services Reform (June 22, 2004) >>>
• Comments regarding Economic Growth and Paperwork Reduction Act “EGRPRA” (April 2004) >>>
• Comments regarding the Proposed Revisions to Regulations B, E, M, Z, DD and the Official Staff Commentaries Docket Numbers R-1167, 1168, 1169, 1170, 1171 (January 2004) >>>
• Supplemental Comments to the Federal Reserve Board’s Solicitation for Comments on Bounce Protection Products (April 2003) >>>
• Comments regarding the proposed rules on Customer Identification Programs for Banks, Savings Associations and Credit Unions >>>