Comment Letters and Testimony

* Most comment letters and testimony below are in PDF format.

• February 20, 2013 NEDAP and allies submit white paper urging the Consumer Financial Protection Bureau to expand and strengthen the Home Mortgage Disclosure Act and ensure that meaningful data on mortgage lending, loan modifications, and mortgage defaults and foreclosures are made public.

• February 15, 2013 NEDAP testifies at hearing of the NYC Council's Committee on Higher Education, on "Examining The Value of For-Profit Colleges."

• December 10, 2012 NEDAP and allies submit comment letter urging the Office of the Comptroller of the Currency to issue Wells Fargo a "Substantial Noncompliance" rating under the Community Reinvestment Act based on the harm Wells Fargo causes New York communities and the bank's failure to meet community credit needs.

New Yorkers Speak Out Against Wells Fargo:

Mr. W - I'm going to continue to fight

Mr. A - In retrospect, I know that I was set up

Mr. R - It's incredibly stressful to be in foreclosure

• November 26, 2012 NEDAP and 33 other members of New Yorkers for Responsible Lending file comment letter calling on the Federal Housing Finance Agency to withdraw its proposal to raise mortgage guarantee fees for New Yorkers.

• October 16, 2012 NEDAP submits comment letter urging the Consumer Financial Protection Bureau to ensure that borrowers are not gouged in the mortgage loan origination process.

• October 9, 2012 NEDAP and 53 other members of New Yorkers for Responsible Lending submit comment letter urging the Consumer Financial Protection Bureau to create strong rules protecting homeowners from mortgage servicing abuses.

• June 29 , 2012 NEDAP and 30 other members of New Yorkers for Responsible Lending submit comment letter urging the Consumer Financial Protection Bureau to create strong rules protecting people from overdraft protection abuses.

• June 28, 2012 NEDAP and allies call for bank and regulatory accountability in comment letter to Office of the Comptroller of the Currency on Capital One's merger with ING Bank. This application is part of Capital One's larger expansion plan that includes its recent purchase of HSBC's $30 billion credit card portfolio.

• June 11, 2012 NEDAP submits memorandum in opposition to A. 8212B / S. 5215C, which would would open the door to abusive for-profit debt settlement companies.

• May 17, 2012 NEDAP testifies at New York State Department of Financial Services hearing on force-placed insurance.

• May 14, 2012 NEDAP and 54 other members of New Yorkers for Responsible Lending submit comment letter urging the NYS Office of Court Administration to strengthen its proposal to address lenders’ violations of court foreclosure rules, which have left thousands of NY homeowners in limbo.

• April 17, 2012 NEDAP and 31 other members of New Yorkers for Responsible Lending submit comment letter urging the Consumer Financial Protection Bureau to provide broad supervision of the debt collection and credit reporting industries.

• January 30, 2012 NEDAP testifies at New York City Council hearing on the foreclosure crisis and its effect on NYC neighborhoods.

• December 19, 2011 NEDAP and allies submit comment letter urging Office of the Comptroller of the Currency to deny Capital One's application to acquire HSBC's $30 billion credit card portfolio. This application is part of Capital One's larger expansion plan that includes its planned purchase of ING Bank.

• December 16 , 2011 NEDAP submits comment letter to new Federal Insurance Office urging the agency to address property insurance redlining. The letter, which NEDAP submitted with 20 other members of New Yorkers for Responsible Lending (NYRL), calls on agency to make public detailed data on where property insurers provide and deny homeowners insurance coverage.

• November 7, 2011 NEDAP testifies before NYS Assembly Committees on Banking, Housing, and Judiciary, on irregularities in the foreclosure process and the impact of the foreclosure crisis on NYC homeowners and neighborhoods.
  

• October 12 , 2011 NEDAP and allies submit comment letter urging Federal Reserve Bank of Richmond to deny Capital One's application to acquire ING Bank.

• August 18, 2011 NEDAP calls for bank and regulatory accountability in comment letter to Federal Reserve Bank of Richmond on Capital One's proposed merger with ING Bank.

• August 15, 2011 NEDAP and 22 other members of the New Yorkers for Responsible Lending (NYRL) coalition submit comment letter urging Consumer Financial Protection Bureau (CFPB) to supervise a broad array of non-bank financial services companies, including debt collectors and consumer reporting agencies, among others.

• August 8, 2011 NEDAP and 23 other members of New Yorkers for Responsible Lending (NYRL) coalition submit comment letter to Office of the Comptroller of the Currency (OCC) urging the OCC to strengthen its proposed guidance for national banks on abusive deposit-related consumer credit products, such as overdraft and direct deposit advance loans.

• July 22, 2011 NEDAP and 49 other members of New Yorkers for Responsible Lending (NYRL) coalition submit comment letter to Federal Reserve Board regarding proposed rules to prevent lenders from making mortgage loans that are unaffordable from their inception.

• July 21, 2011 NEDAP and allies submit comment letter urging the Office of the Comptroller of the Currency to issue JPMorgan Chase a less than satisfactory rating under the Community Reinvestment Act based on Chase's failure to meet community credit needs.

• June 27, 2011 In comment letter to the Office of the Comptroller of the Currency, NEDAP calls on the OCC to withdraw its proposed regulations on the preemption and state enforcement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

• March 7, 2011 NEDAP testifies at joint hearing of the NYC Council's Finance and Community Development Committees, on Responsible Banking ordinance, Intro. No. 485.

• February 28, 2011 NEDAP submits memorandum in opposition to A. 5297A, the "short-term financial services loan act," which would erode New York State's strong consumer protections against abusive loans and open the door to usurious payday lending.

• February 18, 2011 NEDAP testifies at NYC Council Finance and Community Development Committees' hearing on "Proposed Introduction 26-A, a Local Law to amend the administrative code of the City of New York, in relation to the sale of tax liens."

• December 23, 2010 NEDAP joins colleagues in calling on Federal Reserve Board to withdraw proposed rule that would weaken borrowers' remedies against lenders that violate the Truth in Lending Act.

• December 16, 2010 NEDAP testifies before NYC Council's Consumer Affairs Committee on predatory fees, weak consumer protections and other issues associated with prepaid debit cards.

• November 23, 2010 NEDAP testifies before NYC Council's Finance Committee on the need to pass a local Responsible Banking Act.

• November 22, 2010 NEDAP testifies at NYC City Council hearing on foreclosure prevention initiatives.

• November 16, 2010 NEDAP testifies before NYS Assembly Committees on Banking, Housing, and Judiciary, on irregularities in the foreclosure process and the impact of the foreclosure crisis on NYC homeowners and neighborhoods.

• November 5, 2010 In comment letter to the Financial Stability Oversight Council, NEDAP advocates strong and effective implementation of the Volcker Rule provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

• September 28, 2010 NEDAP testifies at City Council hearing on "The Effect of Water and Sewer Lien Sales on Low-Income Residents."

• August 20, 2010 In comment letter to the Federal Reserve Board, NEDAP advocates strengthening and expanding the scope of the Home Mortgage Disclosure Act.

• August 5, 2010 NEDAP testifies at Federal Reserve Board Hearing on proposed changes to the Home Mortgage Disclosure Act.

• July 21, 2010 NEDAP issues statement on passage of federal financial reform.

• July 19, 2010 NEDAP testifies at public hearing convened by federal banking regulators, on changes needed to Community Reinvestment Act regulations.  Click here for testimony, and here to watch video.

• May 6, 2010 NEDAP testifies before the New York City Council Finance Committee on Intro 26—A local law to amend the administrative code of the City of New York in relation to the sale of water liens.

• April 29, 2010 NEDAP submits comment letter to Federal Reserve Board opposing Goldman Sachs' proposed acquisition of SKBHC Holdings, LLC.

• February 3, 2010 NEDAP and allies send joint letter to the Office of the Comptroller of the Currency (OCC), urging the OCC to enforce its regulations regarding banks that make Refund Anticipation Loans (RALs), and calling on the OCC to provide leadership to end RALs lending.

• January 15, 2010 NEDAP and allies file comment letter with the NYS Banking Department in support of proposed Business Conduct Rules for Mortgage Servicers. 

• January 8, 2010 NEDAP submits comments to the Federal Trade Commission regarding debt buyers and their abuse of the courts to collect debt.  NEDAP urges the FTC to investigate and pursue enforcement actions against debt buyers and recommends several amendments to the Fair Debt Collection Practices Act.

• December 24, 2009 NEDAP and other advocacy groups submit comments to Federal Reserve Board on proposed regulations regarding federal Truth in Lending Act.

• October 28, 2009 NEDAP testifies at a public hearing before the NYS Senate Standing Committees on Banks and Codes on residential mortgage fraud.

• October 19, 2009 NEDAP testifies at NYC Council hearing on the impact of tax and water lien sales on seniors and low-income communities.

• October 6, 2009 NEDAP and Empire Justice Center submit joint testimony at a public hearing before the NYS Assembly Committee on Higher Education on the State's new student loan program.  The testimony raises questions about the program and urges the state to strengthen consumer protections to protect low income borrowers or else abandon the program.

• September 9 , 2009 NEDAP and Empire Justice Center submit joint testimony at a public hearing before the Higher Education Services Commission on the State's new student loan program.  The testimony urges the state to strengthen consumer protections to protect low income borrowers.

• June 26, 2009 NEDAP delivers testimony at hearing by NYS Assembly Standing Committee on Banks, on "Discriminatory Mortgage Practices in New York State." NEDAP testimony called on the legislature to pass legislation to regulate mortgage servicers, improve foreclosure settlement confereces, and strengthen protections against abusive practices in the subprime market. 

• June 26, 2009 NEDAP submits comments to the New York City Department of Consumer Affairs regarding proposed rules affecting debt collection practices in New York City.

• June 19, 2009 NEDAP submits letter with 34 groups and 13 elected officials to NYS Banking Superintendent Richard Neiman, calling on agency to deny application by former CEO and other officers of Delta Funding for a mortgage banking license for their new company, Reliance First Capital, LLC. 

• May 14, 2009 Testimony delivered at joint hearing of NYS Assembly Committees on Consumer Affairs and Protection, Banking, and Judiciary, on "Consumer Protection in the Debt Collection and Debt Management Industries." NEDAP testimony called on the NYS Legislature to pass the Consumer Credit Fairness Act, which would protect New Yorkers from abusive debt collection practices.

• April 15, 2009 NEDAP signs on to letter urging the Office of Comptroller of the Currency (OCC) to tighten regulation of national banks that make tax refund anticipation loans (RALS).

• March 30, 2009 Comment letter to Federal Reserve Board on proposed amendments to Regulation E.  NEDAP called on the Board to adopt rules that would prohibit abusive overdraft practices by financial institutions.

• February 25, 2009  Testimony delivered to the New York City Council's Committee on Consumer Affairs, on licensing debt buyers. 

• January 26, 2009  Testimony delivered to the New York City Council's Committee on Consumer Affairs and Committee on Civil Rights on the rent-to-own industry.

• December 18, 2008  Testimony delivered to Office of Thrift Supervision at public hearing on Republic Bank & Trust's application for a federal thrift charter. NEDAP testimony, calling on Office of Thrift Supervision not to approve the application unless Republic ceases funding abusive refund anticipation loans or substantially lowers the cost of these loans.

• December 11, 2008  Testimony delivered to NYS Assembly Standing Committees on Consumer Affairs & Protection and Aging.   NEDAP testimony on financial scams that target low income seniors, calling for heightened standards for, and oversight of, consumer credit filings in New York's courts; significant strengthening of NY's laws governing unfair and deceptive practices; and increased funding for legal services for seniors.

• August 4, 2008  NEDAP comment letter urging Federal Reserve Board to strenthen proposed changes to Regulation AA: Unfair or Deceptive Acts or Practices that would curb abusive credit card and overdraft practices. NEDAP also submitted a joint comment letter with 14 other New York-based groups.

• August 4, 2008  Written testimony delivered to NYC Department of Consumer Affairs, on process server practices that harm low income New Yorkers and deprive them of due process.  The testimony was originally delivered at a public hearing, on June 13, 2008.

• May 12, 2008  Testimony delivered to the New York State Senate Banks Committee, at a hearing on "Evaluating the Governor's Program Bill to Address Mortgage Foreclosures and Subprime Lending in New York State."  NEDAP testimony, calling on the state legislature to pass strong legislation to curb lending abuses in the mortgage market.

• April 29, 2008  Testimony delivered to Federal Reserve Board at public hearing in Los Angeles on Bank of America's proposed acquisition of Countrywide.  NEDAP testimony, calling on Federal Reserve not to approve the acqusition unless Bank of America provides a detailed, concrete plan, in writing, for modifying or otherwise remediating Countrywide's abusive loans, among other steps.

• April 8, 2008  Comment Letter to Federal Reserve Board on proposed revisions to Regulation Z regarding unfair and deceptive mortgage lending practices.  NEDAP comment letter, submitted with South Brooklyn Legal Services, urging Federal Reserve Board to adopt strong, comprehensive mortgage lending regulations.

• April 4, 2008  Comment Letter:  IRS Advanced Notice of Proposed Rulemaking - Regarding Marketing of Refund Anticipation Loans in Connection with the Preparation of a Tax Return  NEDAP comment letter to the IRS regarding the IRS's proposed rulemaking to prohibit tax preparers from disclosing taxpayers' information in order to make them a tax refund anticipation loans (RALs). 

• February 11, 2008  Testimony: U.S. House of Representatives Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit              

NEDAP testimony presented at hearing, "Effects of the Subprime Mortgage Crisis in New York City and Efforts to Help Struggling Homeowners." 

• November 9, 2007  Comments: Federal Trade Commission Workshop, Collecting Consumer Debts:  The Challenges of Change
  NEDAP comment letter to the Federal Trade Commission calling for changes to the Fair Debt Collection Practices Act to address new forms of debt collection harassment, particularly abusive debt collection lawsuits and the freezing of exempt income in bank accounts.

• September 14, 2007  NEDAP signs on to New Yorkers for Responsible Lending comment letter to NYS Banking Department, supporting existing check casher regulations and the continued prohibition on payday lending in New York State.

• July 11, 2007  Testimony: U.S. House of Representatives Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit
  NEDAP testimony presented at hearing, "Overdraft Protection: Fair Practices for Consumers."

• May 29, 2007  Testimony: NYS Assembly Hearing on Subprime Lending & Foreclosures
  NEDAP testimony presented at hearing before the NYS Assembly Standing Committees on Judiciary, Banks, Consumer Affairs and Protection, Housing, Oversight, and Analysis and Investigation.

• May 7, 2007 Federal Regulators' Proposal: Statement on Subprime Mortgage Lending
  NEDAP comment letter on the Federal Reserve, OCC, OTS, and FDIC's statement regarding subprime mortgage lending.

• April 16, 2007  Testimony before the NYS Senate Committee on Consumer Protection and NYS Assembly Committees on Consumer Affairs and Protection, and Banks

NEDAP delivered testimony on abusive credit card and debt collection practices, at the invitation of the NYS Senate and Assembly, which held a joint hearing on the issues, in Albany.

• April 9, 2007  Sign-On Letter: Provisions to Address Tax Refund Lending Abuses

NEDAP participated in the framing of this letter, which addresses abuses in the tax refund anticipation lending industry and suggests provisions to stem these abuses. The letter, signed by organizations nation-wide, was sent to federal legislators.

• January 26, 2007  Public Testimony on the Tax payer Bill of Rights, 1 and 2

Testimony submitted at a public hearing held by the New York City Council Committee on Consumer Affairs, regarding "Int. 81 - in Relation to the Consumer Bill of Rights Regarding Tax Payers." NEDAP testimony focused on Refund Anticipation Loans.

• October 20, 2006  Testimony: Insurance Fund and Data Disclosure Bills

Testimony submitted at a public hearing held by the NYS Assembly Standing Committee on Insurance and Subcommitee on Insurer Investments and Market Practices in Underserved Areas, regarding "Guarding Against Inequities in the Residential Insurance Market and Insurance Company Investments in Underserved Areas of New York State," or Assembly Bills 5737A and 11512.

• October 5, 2006  Testimony: Financial Services for Low-Income Consumers

NEDAP submitted testimony at a public hearing held by the NYS Assembly Standing Committees on Consumer Affairs & Protection and Banks, regarding financial services for low-income consumers in New York.  NEDAP also delivered testimony at the hearing on behalf of New Yorkers for Responsible Lending.  for NYRL testimony.

• October 4, 2006  Testimony: Banks' Discontinuance of Money Service Business Accounts

Testimony submitted at a public hearing held by the NYS Assembly Standing Committees on Consumer Affairs & Protection and Banks, regarding the effect of banks' discontinuance of money service business accounts on low income immigrant New Yorkers.

• June 2006 Proposed Merger Comment Letter: JPMorgan Chase & The Bank of New York

Comment letter, submitted to the Office of the Comptroller of the Currency, in opposition to Chase's application to acquire 338 bank branches, $14.5 billion in deposits and $7.8 in loan balances from The Bank of New York.   NEDAP submitted the letter along with Empire Justice Center, the Foreclosure Prevention Project at South Brooklyn Legal Services, Good Jobs New York, and NYPIRG.

• March 8, 2006 IRS Proposal: Privacy Protections for Taxpayers
  NEDAP comment letter urging the Internal Revenue Service to improve privacy protections for taxpayers utilizing pay-for-service tax preparers.

• November 21, 2005 NYS Banking Dept: Overdraft "Bounce Protection"
  NYRL comment letter in opposition to NYS Banking Department proposal to allow state-chartered financial institutions to strip away existing consumer protections, and enable state-chartered financial insitutions to impose substantially higher charges in their overdraft bounce protection charges.

• September 23, 2005   Bank Charter Proposal: Wal-Mart FDIC Insurance
  NEDAP comment letter to the FDIC opposing Wal-Mart's application to receive insurance for its proposed industrial loan bank charter.

• August 19, 2005   Predatory Lending Proposal: 2005 "Ney-Kanjorski" Bill
  NYRL comment letter in opposition to Ney-Kanjorski bill (H.R. 1295) and in support of Miller-Watt-Frank bill (H.R. 1182).

• August 5, 2005   Amicus Brief: Enforce Fair Lending Laws
  "Friend of the court" brief filed in support of NYS Attorney General Spitzer's efforts to enforce fair lending laws.  Brief filed with 15 other national and New York State groups in the case of Office of the Comptroller of the Currency v. Eliot Spitzer; The Clearinghouse Association, L.L.C. v. Eliot Spitzer.

• May 10, 2005   Federal Regulators' Proposal: Changes to Community Reinvestment Act
  NEDAP comment letter on the Federal Reserve, OCC and FDIC's proposed changes to the Community Reinvestment Act.

• November 19, 2004   Federal Reserve Proposal: Payroll and Stored Value Cards
  RYSE comment letter asking the Federal Reserve Board of Governors to extend consumer protections to cover payroll cards and stored value cards.

• November 4, 2004  2004 NYC Consolidated Plan
  Comment letter in response to New York City's 2004 Proposed Consolidated Plan.
  

• October 20, 2004   FDIC Proposal: Changes to the Community Reinvestment Act
  Comment letter in opposition to the FDIC's proposed changes the definition of small banks in the Community Reinvestment Act (CRA).

• August 6, 2004  Federal Reserve Proposal: Overdraft "Bounce Protection"
  Comment letter in opposition to the Federal Reserve's proposed regulation of bounce protection under the Truth in Savings Act (TISA) instead of the Truth in Lending Act (TILA).

• April 6, 2004   Federal Regulators' Proposal: Changes to the Community Reinvestment Act
  Comment letter in opposition to the OCC, Federal Reserve, FDIC, and OTS's proposed changes to CRA.

• March 15, 2004   Proposed Merger Comment Letter: J.P. Morgan Chase & Bank One
  Comment letter to the Federal Reserve on the proposed merger of Chase and Bank One.
  

• October 6, 2003   OCC Proposal: Preemption of State Law
  Comment letter to the Office of the Comptroller of the Currency opposing rule that would preempt state consumer protections for nationally chartered banks.
  

• June 11, 2003  NYS OTDA Proposal: Electronic Benefits Transfer
  Comment letter to the Office of Temporary and Disability Assistance on Electronic Benefits Transfer (EBT) implementation.

• March 14, 2003   FDIC Proposal: Payday Lending
  Comment letter to the FDIC recommending that regulation of payday lending abuses be strengthened in its Draft Guidelines for Payday Lending.

• January 9, 2003  Proposed Merger Comment Letter: HSBC & Household
  Comment Letter in opposition to HSBC's proposed acquisition of Household International.
  

• July 5, 2002   Proposed Merger Comment Letter: Citigroup & CalFed
  Comment Letter in opposition to Citigroup's proposed acquisition of California Federal Bank (CalFed).

• December 6, 2000  Testimony: NYC Prohibition of ATM Surcharges

Testimony submitted at a public hearing held by the New York City Council, in relation to prohibiting surcharge fees on ATM transactions.

• October 24, 2000   Proposed Merger Comment Letter: Citigroup & Associates
  Comment Letter in opposition to Citigroup's proposed acquisition of Associates National Bank.