[Congressional Record Volume 155, Number 34 (Thursday, February 26, 2009)]
[Senate]
[Pages S2570-S2573]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

      By Mr. DURBIN:
  S. 500. A bill to amend the Truth in Lending Act to establish a 
national usury rate for consumer credit transactions; to the Committee 
on Banking, Housing, and Urban Affairs.
  Mr. DURBIN. As the Congress tries to help Americans overcome the most 
serious economic crisis since the Great Depression, we face two urgent 
yet conflicting priorities. We have to increase demand for American 
products to resuscitate our economy. And we have to reduce the 
financial burden that our children will assume. We need to let 
consumers keep more of their own money without reducing the revenues 
that the government needs to pay for essential services.
  In addition, we need to stop the reckless lending that brought us 
this economic disaster.
  Today, I introduce the Protecting Consumers from Unreasonable Credit 
Rates Act to try to get at each of these goals. My bill sets a ceiling 
of 36 percent annualized interest rates on consumer credit.
  Consumers spend approximately $27 billion every year on predatory 
payday loans, high-cost overdraft loans, and hugely expensive refund 
anticipation loans. Imagine if a portion of that $270 billion 10-year 
cost of credit could be redirected towards buying American goods and 
services. The Center for Responsible Lending estimates that a strong 
federal usury cap would save low-income borrowers $5 billion each year.
  And, in an era that has called for trillions of taxpayer dollars to 
bail out banks and jumpstart economic demand, this proposal costs the 
taxpayers nothing.
  The Protecting Consumers from Unreasonable Credit Rates Act would 
establish a new Federal annualized fee and interest rate calculation--
the FAIR--and institute a 36-percent cap for all types of consumer 
credit.
  In 2006, Congress enacted a Federal 36 percent annualized usury cap 
for certain credit products marketed to military servicemembers and 
their families, which curbed payday, car title, and tax refund lending 
around military bases. My bill would expand on that premise to include 
all types of credit for all borrowers.
  If a lender can't make money on 36 percent interest, then maybe the 
loan shouldn't be made.
  Although I hope to gain widespread support for this bill from 
responsible lenders, I understand that some of the financial service 
firms in this country will be uneasy with a broad bill establishing a 
high interest rate cap. I hope this bill can open an honest 
conversation about consumer credit rates.
  My opening question in that conversation is this: what services do 
you provide for which you can justify charging your customers more than 
36 percent in annual interest?
  Fifteen States and the District of Columbia have already enacted 
broadly applicable usury laws that protect borrowers from high-cost 
payday loans and many other forms of credit, while 34 States and the 
District of Columbia have limited annual interest rates to 36 percent 
or less for one or more types of consumer credit.
  But there is a problem with this State-by-State approach. Those 
limits can sometimes be evaded by out-of-State lenders that are based 
in States that have weaker usury laws.
  Various Federal and State loopholes allow unscrupulous lenders to 
charge cash-strapped consumers pay 400 percent annual interest for 
payday loans on average, 300 percent annual interest for car title 
loans, up to 3500 percent annual interest for bank overdraft loans, 
between 50 and 500 percent annual interest for loans secured by 
expected tax refunds, and higher than 50 percent annual interest for 
credit cards that charge junk fees.
  Consider 66-year-old Rosa Mobley, who lives on Social Security and a 
small pension.
  The Chicago Tribune reports that Ms. Mobley took out a car title 
loan--a type of payday loan in which the borrowers put up their cars as 
collateral--for $1,000. Ms. Mobley was charged 300 percent interest.
  She wound up paying more than $4,000 over 28 months and at the time 
of the report was struggling just to get by.
  This bill would require that all fees and finance changes be included 
in the new usury rate calculation and would require all lending to 
conform to the limit, thereby eliminating the many loopholes that have 
allowed these predatory practices to flourish.
  It would not preempt stronger State laws, it would allow State 
attorneys general to help enforce this new rate cap, and it would 
provide for strong

[[Page S2571]]

civil penalties to deter lender violations.
  I included in this bill the flexibility for responsible lenders to 
replace payday loans that some borrowers once relied on with reasonably 
priced, small-dollar loan alternatives. The bill allows lenders to 
exceed the 36 percent usury cap for one-time application fees that 
cover the costs of setting up a new customer account and for processing 
costs such as late charges and insufficient funds fees.
  The Protecting Consumers from Unreasonable Credit Rates Act would 
eliminate predatory lenders, but it also would help borrowers make 
smarter choices.
  Congress established the Truth in Lending Act over 40 years ago to 
help consumers compare the costs of borrowing when buying a home, a 
car, or other items by establishing a standard Annual Percentage Rate 
that all lenders should advertise.
  My first mentor in politics, the late Senator Paul Douglas from my 
home State of Illinois, said all the way back in 1963 that too often 
lenders:

     compound the camouflaging of credit by loading on all sorts 
     of extraneous fees, such as exorbitant fees for credit life 
     insurance, excessive fees for credit investigation, and all 
     sorts of loan processing fees which rightfully should be 
     included in the percentage rate statement so that any 
     percentage rate quoted is meaningless and deceptive.

  That was before anyone had ever heard of ``subprime lending.''
  Unfortunately, as the use of credit has exploded and as the 
complexity of the credit products offered by lenders has become mind-
boggling, Congress and the Federal Reserve have taken several actions 
since the passage of Truth in Lending to weaken the APR as a tool for 
comparison shopping. Today, many fees can be excluded from the rate 
that is given to borrowers. The APR no longer gives consumers the 
convenient and accurate information it once did. One payday lender in 
Pennsylvania used the various exclusions to disclose what was really a 
400 percent APR as 6 percent.
  This bill would give consumers a way to accurate compare credit 
options, by requiring that the new FAIR calculation be disclosed both 
for open-end credit plans such as credit cards and for closed-end 
credit such as mortgages and payday loans.
  The bill is supported by 100 groups at the national and local levels, 
including the Consumer Federation of American, the National Consumer 
Law Center, the Center for Responsible Lending, USPIRG, and Consumers 
Union, and I include a copy of their letter of support for the 
Congressional Record.
  As Congress considers some very complicated economic challenges, I 
urge my colleagues to also consider simple solutions. We can help give 
more money to American consumers today without borrowing money that 
must be repaid tomorrow. Let's start by eliminating some of the worst 
abuses in lending by establishing a reasonable fee and interest rate 
cap.
  I urge my colleagues to support the Protecting Consumers from 
Unreasonable Credit Rates Act.
  I ask unanimous consent that the text of the bill and the letter of 
support be printed in the Record.
  There being no objection, the material was ordered to be printed in 
the Record, as follows:

                                 S. 500

       Be it enacted by the Senate and House of Representatives of 
     the United States of America in Congress assembled,

     SECTION 1. SHORT TITLE.

       This Act may be cited as the ``Protecting Consumers from 
     Unreasonable Credit Rates Act of 2009''.

     SEC. 2. FINDINGS.

       Congress finds that--
       (1) attempts have been made to prohibit usurious interest 
     rates in America since colonial times;
       (2) at the State level, 15 states and the District of 
     Columbia have enacted broadly applicable usury laws that 
     protect borrowers from high-cost payday loans and many other 
     forms of credit, while 34 states and the District of Columbia 
     have limited annual interest rates to 36 percent or less for 
     1 or more types of consumer credit;
       (3) at the Federal level, in 2006, Congress enacted a 
     Federal 36 percent annualized usury cap for service members 
     and their families for covered credit products, as defined by 
     the Department of Defense, which curbed payday, car title, 
     and tax refund lending around military bases;
       (4) notwithstanding such attempts to curb predatory 
     lending, high cost lending persists in all 50 States due to 
     loopholes in State laws, safe harbor laws for specific forms 
     of credit, and the exportation of unregulated interest rates 
     permitted by preemption;
       (5) due to the lack of a comprehensive Federal usury cap, 
     consumers annually pay approximately $17,500,000,000 for 
     high-cost overdraft loans, as much as $8,600,000,000 for 
     storefront and online payday loans, and nearly $900,000,000 
     for tax refund anticipation loans;
       (6) cash-strapped consumers pay on average 400 percent 
     annual interest for payday loans, 300 percent annual interest 
     for car title loans, up to 3,500 percent for bank overdraft 
     loans, 50 to 500 percent annual interest for loans secured by 
     expected tax refunds, and higher than 50 percent annual 
     percentage interest for credit cards that charge junk fees;
       (7) a national maximum interest rate that includes all 
     forms of fees and closes all loopholes is necessary to 
     eliminate such predatory lending; and
       (8) alternatives to predatory lending that encourage small 
     dollar loans with minimal or no fees, installment payment 
     schedules, and affordable repayment periods should be 
     encouraged.

     SEC. 3. NATIONAL MAXIMUM INTEREST RATE.

       The Truth in Lending Act (15 U.S.C. 1601 et seq.) is 
     amended by adding at the end the following:

     ``SEC. 141. MAXIMUM RATES OF INTEREST.

       ``(a) In General.--Notwithstanding any other provision of 
     law, no creditor may make an extension of credit to a 
     consumer with respect to which the fee and interest rate, as 
     defined in subsection (b), exceeds 36 percent.
       ``(b) Fee and Interest Rate Defined.--
       ``(1) In general.--For purposes of this section, the fee 
     and interest rate includes all charges payable, directly or 
     indirectly, incident to, ancillary to, or as a condition of 
     the extension of credit, including--
       ``(A) any payment compensating a creditor or prospective 
     creditor for--
       ``(i) an extension of credit or making available a line of 
     credit, such as fees connected with credit extension or 
     availability such as numerical periodic rates, annual fees, 
     cash advance fees, and membership fees; or
       ``(ii) any fees for default or breach by a borrower of a 
     condition upon which credit was extended, such as late fees, 
     creditor-imposed not sufficient funds fees charged when a 
     borrower tenders payment on a debt with a check drawn on 
     insufficient funds, overdraft fees, and over limit fees;
       ``(B) all fees which constitute a finance charge, as 
     defined by rules of the Board in accordance with this title;
       ``(C) credit insurance premiums, whether optional or 
     required; and
       ``(D) all charges and costs for ancillary products sold in 
     connection with or incidental to the credit transaction.
       ``(2) Tolerances.--
       ``(A) In general.--With respect to a credit obligation that 
     is payable in at least 3 fully amortizing installments over 
     at least 90 days, the term `fee and interest rate' does not 
     include--
       ``(i) application or participation fees that in total do 
     not exceed the greater of $30 or, if there is a limit to the 
     credit line, 5 percent of the credit limit, up to $120, if--

       ``(I) such fees are excludable from the finance charge 
     pursuant to section 106 and regulations issued thereunder;
       ``(II) such fees cover all credit extended or renewed by 
     the creditor for 12 months; and
       ``(III) the minimum amount of credit extended or available 
     on a credit line is equal to $300 or more;

       ``(ii) a late fee charged as authorized by State law and by 
     the agreement that does not exceed either $20 per late 
     payment or $20 per month; or
       ``(iii) a creditor-imposed not sufficient funds fee charged 
     when a borrower tenders payment on a debt with a check drawn 
     on insufficient funds that does not exceed $15.
       ``(B) Adjustments for inflation.--The Board may adjust the 
     amounts of the tolerances established under this paragraph 
     for inflation over time, consistent with the primary goals of 
     protecting consumers and ensuring that the 36 percent fee and 
     interest rate limitation is not circumvented.
       ``(c) Calculations.--
       ``(1) Open end credit plans.--For an open end credit plan--
       ``(A) the fee and interest rate shall be calculated each 
     month, based upon the sum of all fees and finance charges 
     described in subsection (b) charged by the creditor during 
     the preceding 1-year period, divided by the average daily 
     balance; and
       ``(B) if the credit account has been open less than 1 year, 
     the fee and interest rate shall be calculated based upon the 
     total of all fees and finance charges described in subsection 
     (b)(1) charged by the creditor since the plan was opened, 
     divided by the average daily balance, and multiplied by the 
     quotient of 12 divided by the number of full months that the 
     credit plan has been in existence.
       ``(2) Other credit plans.--For purposes of this section, in 
     calculating the fee and interest rate, the Board shall 
     require the method of calculation of annual percentage rate 
     specified in section 107(a)(1), except that the amount 
     referred to in that section 107(a)(1) as the `finance charge' 
     shall include all fees, charges, and payments described in 
     subsection (b)(1).
       ``(3) Adjustments authorized.--The Board may make 
     adjustments to the calculations in paragraphs (1) and (2), 
     but the primary goals of such adjustment shall be to protect 
     consumers and to ensure that the 36 percent

[[Page S2572]]

     fee and interest rate limitation is not circumvented.
       ``(d) Definition of Creditor.--As used in this section, the 
     term `creditor' has the same meaning as in section 702(e) of 
     the Equal Credit Opportunity Act (15 U.S.C. 1691a(e)).
       ``(e) No Exemptions Permitted.--The exemption authority of 
     the Board under section 105 shall not apply to the rates 
     established under this section or the disclosure requirements 
     under section 127(b)(6).
       ``(f) Disclosure of Fee and Interest Rate for Credit Other 
     Than Open End Credit Plans.--In addition to the disclosure 
     requirements under section 127(b)(6), the Board may prescribe 
     regulations requiring disclosure of the fee and interest rate 
     established under this section in addition to or instead of 
     annual percentage rate disclosures otherwise required under 
     this title.
       ``(g) Relation to State Law.--Nothing in this section may 
     be construed to preempt any provision of State law that 
     provides greater protection to consumers than is provided in 
     this section.
       ``(h) Civil Liability and Enforcement.--In addition to 
     remedies available to the consumer under section 130(a), any 
     payment compensating a creditor or prospective creditor, to 
     the extent that such payment is a transaction made in 
     violation of this section, shall be null and void, and not 
     enforceable by any party in any court or alternative dispute 
     resolution forum, and the creditor or any subsequent holder 
     of the obligation shall promptly return to the consumer any 
     principal, interest, charges, and fees, and any security 
     interest associated with such transaction. Notwithstanding 
     any statute of limitations or repose, a violation of this 
     section may be raised as a matter of defense by recoupment or 
     setoff to an action to collect such debt or repossess related 
     security at any time.
       ``(i) Violations.--Any person that violates this section, 
     or seeks to enforce an agreement made in violation of this 
     section, shall be subject to, for each such violation, 1 year 
     in prison and a fine in an amount equal to the greater of--
       ``(1) 3 times the amount of the total accrued debt 
     associated with the subject transaction; or
       ``(2) $50,000.
       ``(j) State Attorneys General.--An action to enforce this 
     section may be brought by the appropriate State attorney 
     general in any United States district court or any other 
     court of competent jurisdiction within 3 years from the date 
     of the violation, and such attorney general may obtain 
     injunctive relief.''.

     SEC. 4. DISCLOSURE OF FEE AND INTEREST RATE FOR OPEN END 
                   CREDIT PLANS.

       Section 127(b)(6) of the Truth in Lending Act (15 U.S.C. 
     1637(b)(6)) is amended by striking ``the total finance charge 
     expressed'' and all that follows through the end of the 
     paragraph and inserting ``the fee and interest rate, 
     displayed as `FAIR', established under section 141.''.

   Diverse National and State Groups Support Durbin/Speier FAIR Bill

                                                February 25, 2009.
     Hon. Richard J. Durbin,
     Hart Senate Bldg.,
     Washington, DC.
     Hon. Jackie Speier,
     Cannon House Office Bldg.,
     Washington, DC.
       Dear Senator Durbin and Representative Speier: We applaud 
     Senator Durbin and Representative Speier for proposing a 
     measure that would stop a wide range of lending abuses by 
     capping interest rates for consumer credit at 36 percent 
     annually. Cleaning up the finance industry is essential to a 
     sustainable economic recovery.
       The ``Protecting Consumers from Unreasonable Credit Rates 
     Act'' would implement a key promise made by President Obama 
     to extend to all Americans Congressional protection against 
     predatory lending for Service members and their families. By 
     limiting the total cost of consumer credit to 36 percent, 
     Congress will keep billions of dollars in the hands of low 
     and moderate-income consumers, helping to stimulate the 
     economy without costing taxpayers a penny.
       This measure is designed to keep affordable financial 
     products available, as lenders who offer sustainable loans do 
     so at rates well below 36 percent annually. But it would 
     eliminate abuses that rely on high fees, interest and other 
     devices to charge extremely high annual rates--some 400 
     percent and higher--to trap consumers in debt they cannot 
     afford to pay off.
       Protections that once curbed abusive lending in America 
     have been shredded, and consumers are paying astronomical 
     rates for credit, especially those who have the fewest 
     resources. Payday loans cost 400 percent APR or higher; car 
     title loans cost 300 percent APR and put car ownership at 
     risk; loans secured by expected tax refunds cost 50 to 500 
     percent APR; and credit card fees and interest can combine to 
     produce triple-digit rates. Bank overdraft loans can cost 
     quadruple digit interest rates. These extremely expensive 
     credit products drain billions from families who struggle to 
     make ends meet, diminishing their ability to purchase 
     products and services that would boost the economy.
       The ability of states to enact meaningful reforms on credit 
     card and bank overdraft practices has been severely 
     restricted as a result of federal preemption. Banks are now 
     permitted to locate in a state without consumer protections 
     and then engage in unregulated lending in the other forty-
     nine states, which are powerless to protect their citizens 
     against high cost credit cards and tax refund anticipation 
     loans. State usury caps have been riddled with loopholes and 
     exceptions, leaving consumers in thirty-five states exposed 
     to outrageously expensive payday loans.
       The FAIR (Fees and Interest Rate) cap on consumer credit is 
     set high enough not to hamper mainstream responsible lending. 
     A 36 percent rate cap is twice the limit for federally-
     chartered credit unions and enables credit to be responsibly 
     extended to consumers with less than perfect credit ratings. 
     This is the rate cap enacted by Congress through the Military 
     Lending Act and is the limit typically used in state small 
     loan laws. The FAIR cap will be the maximum amount lenders 
     can charge, but states will be able to set lower rate caps to 
     protect their citizens, such as New York's 25 percent 
     criminal cap and Arkansas's constitutional cap.
       We urge quick action to implement the FAIR cap to stop 
     usurious credit rates, to protect struggling consumers, and 
     to put all lenders under the same set of protections.
           Sincerely,
       Jean Ann Fox, Consumer Federation of America.
       Pam Banks, Consumers Union.
       Lauren Saunders, National Consumer Law Center (on behalf of 
     its low income clients).
       Edmund Mierzwinski, U. S. Public Interest Research Group.
       Michael Calhoun, Center for Responsible Lending.
       David Berenbaum, National Community Reinvestment Coalition.
       Hilary O. Shelton, NAACP.
       Linda Sherry, Consumer Action.
       Sally Greenberg, National Consumers League.
       Don Mathis, Community Action Partnership.
       Jim Campen, Americans For Fairness in Lending.
       Maude Hurd, Association of Community Organizations for 
     Reform Now (ACORN).
       George Goehl, National Training and Information Center.
       Ira Rheingold, National Association of Consumer Advocates 
     (NACA).
       Jerily DeCoteau, First Nations Development Institute.
       Joanna Donohoe, Oweesta Corporation.
       Lisa Rice, National Fair Housing Alliance.
       Rosemary Shahan, Consumers for Auto Reliability and Safety.
       Steve Hitov, National Health Law Program (NHeLP).
       Jacqueline Johnson Pata, National Congress of American 
     Indians.
       Joe Rich, Lawyers' Committee for Civil Rights Under Law.


                          State Organizations

       Shay Farley, Alabama Appleseed.
       Barbara Williams, Alaska Injured Workers Alliance Research 
     and Development Corp.
       Diane E. Brown, Arizona Public Interest Research Group.
       Leslie Kyman Cooper, Arizona Consumers Council.
       Al Sterman, Democratic Processes Center, Arizona.
       Karin Uhlich, Southwest Center for Economic Integrity, 
     Arizona.
       H.C. ``Hank'' Klein, Arkansans Against Abusive Payday 
     Lending, Arkansas.
       Jim Bliesner, San Diego City/County Reinvestment Task 
     Force, California.
       Betsy Handler, Inner City Law Center, Los Angeles, 
     California.
       Richard Holober, Consumer Federation of California.
       Kimberly Jones and Liana Molina, California Reinvestment 
     Coalition.
       Kyra Kazantzis, Public Interest Law Firm, Fair Housing Law 
     Project, San Jose, CA
       M. Stacey Hawver, Legal Aid Society of San Mateo County, 
     CA.
       Raphael L. Podolsky, Legal Assistance Resource Center of 
     Connecticut, Inc. Lynn Drysdale, Jacksonville Area Legal Aid, 
     Inc., Florida.
       Bill Newton, Florida Consumer Action Network.
       Sally G. Schmidt, Florida Equal Justice Center.
       Victor Geminani, Lawyers for Equal Justice, Hawaii.
       Don Carlson, Central Illinois Organizing Project, Illinois.
       Lynda DeLaforgue and William McNary, Citizen Action/
     Illinois.
       Rose Mary Meyer, Project IRENE, Illinois.
       Dory Rand, Woodstock Institute, Illinois.
       Madeline Talbott, Action Now, Illinois.
       Brian C. White, Lakeside Community Development Corporation, 
     Illinois.
       Victor Elias, Child and Family Policy Center and Iowa 
     Coalition Against Abusive Lending, Iowa.
       Larry M. McGuire, Minister, Community of Christ and Inter-
     Religious Council of Linn County, Iowa.
       Lana L. Ross, Iowa Community Action Association.
       Jason Selmon, Sunflower Community Action, Kansas.
       Terry Brooks, Kentucky Youth Advocates.
       Dana Jackson, Making Connections Network, Louisville, 
     Kentucky.
       Melissa Fry Konty, Mountain Association for Community 
     Economic Development, Kentucky.
       Anne Marie Regan and Rich Seckel, Kentucky Equal Justice 
     Center.
       Amy Shir, Kentucky Asset Building Coalition.
       Debra Gardner, Public Justice Center, Maryland.
       Charles Shafer, Maryland Consumer Rights Coalition.

[[Page S2573]]

       Debra Fastino, The Coalition for Social Justice, 
     Massachusetts.
       Jim Breslauer, Neighborhood Legal Services, Lawrence, 
     Massachusetts.
       Caroline Murray, Alliance to Develop Power/ADP Worker 
     Center, Massachusetts Paheadra B. Robinson, Mississippi 
     Center for Justice.
       Robin Acree, GRO-Grassroots Organizing, Missouri.
       Mike Cherry, Consumer Credit Counseling Service, Missouri.
       Mike Ferry, Gateway Legal Services, Inc., Missouri, 
     Arkansas, and Illinois.
       Linda Gryczan, Montana Business and Professional Women, 
     Montana Women's Lobby
       Linda E. Reed, Montana Community Foundation.
       Michele Johnson, Consumer Credit Counseling Service, Nevada 
     and Utah
       Dan Wulz, Legal Aid Center of Southern Nevada.
       Paula J. O'Brien, New York State Consumer Protection Board.
       Josh Zinner and Sarah Ludwig, Neighborhood Economic 
     Development Advocacy Project, New York.
       Al Ripley, North Carolina Justice Center.
       Jeffrey D. Dillman, Housing Research and Advocacy Center, 
     Ohio.
       Bill Faith, Coalition on Homelessness and Housing in Ohio.
       Jim McCarthy, Miami Valley Fair Housing Center, Inc., Ohio.
       David Rothstein, PolicyMatters, Ohio.
       Jeff Shuman, Deep Fork Community Action, Oklahoma.
       Linda Burgin, SEIU Local 503, Oregon.
       Linda Burgin, SEIU Oregon State Council.
       Jerry Cohen, AARP Oregon.
       Alice Dale, SEIU Local 49, Oregon.
       Angela Martin, Our Oregon.
       Kerry Smith, Community Legal Services, Pennsylvania.
       Sue Berkowitz, South Carolina Appleseed Legal Justice 
     Center.
       Rena Eller, Senior Citizens of Hendersonville, Inc.
       Dana M. Given, United Way of Sumner County, Tennessee.
       Corky Neale, RISE Foundation and Memphis Responsible 
     Lending Collaborative, TN.
       Karen Pershing, United Way of Greater Knoxville, Tennessee.
       Sherry Tolli, Home Safe of Sumner, Wilson and Robertson 
     Counties, Inc., Tennessee.
       Carlos Gallinar, La Fe Community Development Corporation, 
     El Paso, Texas.
       Regina Harvey, Dominion Financial Management, Smyrna, 
     Texas.
       Linda Hilton, Coalition of Religious Communities, Utah.
       Janice ``Jay'' Johnson, Virginia Organizing Project.
       Irene E. Leech, Virginia Citizens Consumer Council.
       LaTonya Reed and C. Douglas Smith, Virginia Interfaith 
     Center.
       Ward Scull and Mike Lane, Virginians against Payday 
     Lending.
       James W. Speer, Virginia Poverty Law Center.
       Dana Wiggins, Virginia Partnership to Encourage Responsible 
     Lending.
       Maya Baxter, Statewide Poverty Action Network, Washington.
       John R. Jones, Washington ACORN.
       Bruce Neas, Columbia Legal Services, Washington, on behalf 
     of clients.
       Will Pittz, Washington Community Action Network.

                          ____________________