US Homelessness Increases 18.1% as Many Lack Affordable Housing

The U.S. had an 18.1% increase in homelessness in 2024, a dramatic rise driven mostly by a lack of affordable housing as well as devastating natural disasters and a surge of migrants in several parts of the country. The U.S. Department of Housing and Urban Development said federally required tallies taken across the country - the annual Point-In-Time (PIT) Count - in January found that over 770,000 were counted as homeless. This number misses some people and does not include those staying with friends or family because they do not have a place of their own.

The source of the data was Part 1: Point-In-Time Estimates of Homelessness of HUD's The 2024 Annual Homelessness Assessment Report (AHAR) to Congress, an annual report to Congress providing nationwide estimates of homelessness, including information about the demographic characteristics of homeless persons, service use patterns, and the capacity to house homeless persons. HUD released it on December 27, 2024.

2024's 18.1% increase comes after 2023's 12.0% increase, which HUD said was caused by soaring rents, the end of pandemic assistance, and by people experiencing homelessness for the first time. The numbers overall represent 23 of every 10,000 people in the U.S., with Black people being overrepresented among the homeless population.

Among the most serious trends was a nearly 40% rise in family homelessness - among the areas most affected by the arrival of migrants in big cities. Family homelessness more than doubled in 13 communities impacted by migrants including Denver, Chicago, and New York City, while it rose less than 8% in the other 373 communities. Almost 150,000 children were homeless on a single night in 2024, a 33% jump from last year. California, the most populous state, continued to have the nation’s largest homeless population, followed by New York, Washington, Florida and Massachusetts.

According to the National Low Income Housing Coalition (NLIHC), to fully address America’s affordable housing and homelessness crisis, "Congress must invest at the scale needed to ensure that renters with the lowest incomes have an affordable place to call home. As outlined in NLIHC’s national HoUSed campaign policy agenda, federal investments are needed to bridge the gap between incomes and housing costs through universal rental assistance, build and preserve rental homes affordable to people with the lowest incomes, prevent evictions and homelessness by stabilizing families during a crisis, and strengthen and enforce renter protections to address the power imbalance that tilts heavily in favor of landlords."

While the data presents a grim picture, it also "demonstrates that success is possible when the federal government prioritizes evidence-based solutions and funds these resources to scale," said the National Alliance to End Homelessness (NAEH). One notable example is the reduction in veteran homelessness. From 2023 to 2024, veteran homelessness dropped by 7.6%, with unsheltered veteran homelessness falling 10.7%. This marks the continuation of a successful federal strategy that has reduced veteran homelessness by over 55% since 2010, one of the most significant achievements in the fight to end homelessness. In addition, several large cities had success reducing their homeless numbers. Dallas, which overhauled its homeless system, saw a 16% drop during 2022-2024. Los Angeles, which increased housing for the homeless, had a 5% decrease in unsheltered homelessness since 2023.

Read the December 27, 2024 AP News Article.

Read the December 27, 2024 NLIHC's full statement.

Read the December 27, 2024 NAEH article.

Senator Smith (D-MN) Introduces “Mapping Housing Discrimination Act”

Senator Tina Smith (D-MN) has introduced the “Mapping Housing Discrimination Act” (S.5534) in the U.S. Senate last week. The bill would support efforts to map and digitize data on racially restrictive covenants in property records and establish a grant program to enable educational institutions to collect and analyze racial covenants and racially or ethnically restrictive language in local governments’ property records. The legislation would also help local governments digitize deeds and would create a publicly accessible database administered by HUD to gather together information about historic housing discrimination patterns in property records.  

The National Low Income Housing Coalition (NLIHC) has endorsed the legislation and will work with Senator Smith’s office to support efforts to document the impacts of racial covenants and other tools of discrimination used to keep Black families and other households of color from moving into certain neighborhoods. While such racial covenants were made illegal by the Fair Housing Act of 1968, documenting such records is crucial to tracking the history of housing discrimination, along with the impacts of housing segregation that persist today.  

Senator Smith also introduced a similar bill in July, 2021, that would examine the connection between historical racial discrimination and current racial disparities in housing. The bill would have created "a grant program for academic institutions to study the history of racially restrictive covenants - which were used as tools of discrimination to keep Black families and other households of color from moving into all-white neighborhoods - to better understand their scope and legacy. The bill would create a national, public database at HUD of historical housing discrimination patterns in property records and support local governments’ efforts to digitize local property records."

Read the 2024 bill text here. 

Read more about the history of fair housing in “Lofty Rhetoric, Prejudiced Policy: The Story of How the Federal Government Promised— and Undermined—Fair Housing” in NLIHC’s 2024 Advocates’ Guide.  

Recent Data on Maryland: Housing is Unaffordable for Many

Shortage of Affordable Housing

According to the June, 2024 "Maryland Housing Profile" compiled by the National Low Income Housing Coalition (NLIHC), Maryland has "a shortage of rental homes affordable and available to extremely low income households (ELI), whose incomes are at or below the poverty guideline or 30% of their area median income (AMI). Many of these households are severely cost burdened, spending more than half of their income on housing. Severely cost burdened poor households are more likely than other renters to sacrifice other necessities like healthy food and healthcare to pay the rent, and to experience unstable housing situations like evictions." The statistics are stark:

197,310 or 26% - .Renter households that are extremely low income.

-134,192 - Shortage of rental homes affordable and available for extremely low income renters.

$37,740 - Average income limit for 4-person extremely low income household.

$76,345 - Annual household income needed to afford a two-bedroom rental home at HUD's Fair Market Rent.

73% - Percent of extremely low income renter households with severe cost burden.

According to the NLIHC's Out of Reach: The High Cost of Housing (2024), working at minimum wage of $15.00/hour each week you have to work 82 hours to afford a modest 1 bedroom rental home at the State's Fair Market Rent. In Maryland, the Fair Market Rent (FMR) for a two-bedroom apartment is $1,909. In order to afford this level of rent and utilities - without paying more than 30% of income on housing - a household must earn $6,362 monthly or $76,345 annually. Assuming a 40-hour work week, 52 weeks per year, this level of income translates into an hourly Housing Wage of $36.70.

Read the Maryland profile in the NLIHC's Out of Reach report.

Housing Inventory Characteristics

In 2019-2023, Maryland had a total of 2.5 million housing units. Of these housing units:

72.4% were single-family houses either not attached to any other structure or attached to one or more structures (commonly referred to as "townhouses" or "row houses"). 

26.2% of the housing units were located in multi-unit structures, or those buildings that contained two or more apartments. 

1.3% were mobile homes, while any remaining housing units were classified as "other," which included boats, recreational vehicles, vans, etc.

When was the Housing Built?

8.6% of the housing inventory was comprised of houses built since 2010, while 10.8% of the houses were first built in 1939 or earlier. The median number of rooms in all housing units in Maryland was 6.2 rooms, and of these housing units 66.4 percent had three or more bedrooms (Source: DP04 | Selected Housing Characteristics).

Occupied Housing Characteristics

In 2019-2023, Maryland had 2.3 million housing units that were occupied or had people living in them, while the remaining 206,022 were vacant. 

Of the occupied housing units, the percentage of these houses occupied by owners (also known as the homeownership rate) was 67.5% while renters occupied 32.5%. The average household size of owner-occupied houses was 2.70 and in renter-occupied houses it was 2.34.

Some 9.3% of householders of these occupied houses had moved into their house since 2021, while 10.9% moved into their house in 1989 or earlier. Households without a vehicle available for personal use comprised 8.7% and another 22.1% had three or more vehicles available for use (Source: DP04 | Selected Housing Characteristics).

Financial Characteristics and Housing Costs

In 2019-2023, the median property value for owner-occupied houses in Maryland was $397,700.

Of the owner-occupied households, 71.5% had a mortgage. 28.5% owned their houses "free and clear," that is without a primary mortgage or loan on the house. The median monthly housing costs for owners with a mortgage was $2,301 and for owners without a mortgage it was $728.

For renter-occupied households, the median gross rent for Maryland was $1,662. Gross rent includes the monthly contract rent and any monthly payments made for electricity, gas, water and sewer, and any other fuels to heat the house (Source: DP04 | Selected Housing Characteristics).

Disability

In Maryland, among the civilian noninstitutionalized population in 2019-2023, 11.4% reported a disability. The likelihood of having a disability varied by age - from 4.3% of people under 18 years old, to 9.2% of people 18 to 64 years old, and to 29.6% of those 65 and over (Source: DP02 | Selected Social Characteristics in the United States).

Go to the Census Bureau's 1999-2023 Maryland Narrative Profile.

Maryland Commission on Civil Rights' Symposium on Protecting Civil Rights is January 11th

 

Tuesday, December 24, 2024 The Maryland Commission on Civil Rights (MCCR) is honored to invite you to join us at our upcoming symposium, "Protecting Civil Rights During Challenging Times." The symposium will be held on Saturday, January 11, 2025 from 9:00am-3:00pm at Howard Community College. This event is free of charge with lunch provided. REGISTER TODAY We will focus on addressing civil rights challenges in today's uncertain environment and the collaborative efforts needed to safeguard equity and justice for all Marylanders. Our guests include representatives from the Office of the Attorney General of Maryland, the Governor's Office, the U.S. Attorney's Office, and more! Thank you for your continued support of the Maryland Commission on Civil Rights as we strive to break barriers, uplift voices, and create even greater change! Victim of Discrimination? Training & Partnerships HOME      ABOUT MCCR      SERVICES      PUBLICATIONS      EVENTS      PRESS      CONTACT US

DRM and Partners Reach Agreement with Baltimore City to Improve Sidewalks and Ramps for People with Mobility Disabilities

 

Disability Rights Maryland (DRM) and their legal partners Disability Rights Advocates, Fox & Robertson, and Goldstein, Borgen, Dardarian & Ho, on behalf of pedestrians with mobility disabilities, have reached a partial agreement with the City of Baltimore to make sidewalks and curb ramps more accessible for people with mobility disabilities. This is part of the class-action lawsuit Goodlaxson, et al. v. Mayor and City Council of Baltimore (Case No. 1:21-cv-01454-JKB).    In 2021, DRM and their legal partners filed the lawsuit on behalf of several individuals and organizations, including Susan Goodlaxson, Janice Jackson, Keyonna Mayo, and the IMAGE Center of Maryland. They argued that Baltimore City failed to follow federal disability laws because many of its sidewalks and curb ramps were not built or maintained to be accessible, making it harder for people with disabilities to safely travel around the city and take part in community life.    Baltimore City’s own data shows the issue is widespread. A 2019 review found that only about 1.3% of surveyed curb ramps met ADA (Americans with Disabilities Act) standards. Many sidewalks were also damaged or too narrow for wheelchairs and other mobility devices, forcing people with disabilities to use the street alongside traffic, which is dangerous.    This lawsuit aimed to help everyone with mobility disabilities who has had difficulty using Baltimore’s sidewalks, curb ramps, and pedestrian pathways because they were too steep, narrow, or damaged. The agreement, a partial consent decree, is a step toward fixing these problems. Beginning in the third year of the agreement, the parties will work on a long-term plan to make all sidewalks and ramps accessible.

What Baltimore City Agreed to Do:   Spend $44–50 Million Over Four Years  The City will repair or build thousands of curb ramps and fix tens of thousands of square feet of sidewalks. Focus on Key Areas First Improvements will start in important places like government offices, transportation hubs, hospitals, and business areas -  especially in high-need neighborhoods. Improve the 3-1-1 System People with mobility disabilities can use the City’s 3-1-1 system to report broken sidewalks or ramps. Baltimore City will: Investigate issues within 60 days.  Provide a timeline for fixing the issue within 10 days after the investigation. Aim to fix the problem within nine months.  Quickly respond to complaints about puddles forming on ramps.  Hire ADA Coordinators  Baltimore will appoint coordinators to ensure the repairs meet ADA standards. Raise Awareness The City will educate the public about keeping sidewalks and ramps clear of snow and debris, especially near bus stops and public transportation. Create a Public Database  Baltimore City will maintain an online system to track the conditions of sidewalks and curb ramps.

Source: Disability Rights Maryland email, December 19, 2024

Bazelon Successfully Advocates for Federal Medicaid Dollars to Go to Community Integration, Not Segregated Settings

On December 16, 2024, the Judge David L. Bazelon Center applauded the Centers for Medicare & Medicaid Services (CMS) for prioritizing community integration, quality healthcare, and oversight in considering California’s recent proposal to use federal dollars provided through Medicaid to build and operate segregated, residential settings that do not meet the state’s legal requirement to provide services to people with disabilities in the most integrated setting.

On August 30, 2024, Bazelon had filed comments with CMS expressing deep concerns about California’s proposal to use Medicaid dollars to build congregate settings, referred to as “enriched residential settings” (ERS), that would be populated exclusively or primarily by people with disabilities whose activities would be regulated and other restrictions imposed. The ADA and Olmstead v. L.C. (Lois Curtis) require that individuals with disabilities be served in the most integrated setting appropriate and not unnecessarily provided institutional care. 

Bazelon's comments argued that California has not made and is not making mainstream housing, subsidized and with appropriate supports, available to those it proposes to serve in ERS. In Bazelon's experience, these individuals could be served in such settings, like “supported housing,” with better results. Evidence and research also was cited that showed that a step-down model or “linear continuum of care” - where people with mental health disabilities are moved through temporary congregate settings before they are transitioned to independent housing - is not necessary nor effective. At a minimum, CMS was urged to impose guardrails limiting the use and size of these segregated, residential settings.

There was immediate progress. This month, in responding to the state’s application for funding, CMS denied California’s request for federal funding of ERS and instructed California to first develop, seek public comment on, and submit additional details on critical related issues such as how the proposed pilot will ensure people are placed in the least restrictive setting and how it will confirm service settings are committed to being truly integrated, with independent choice. Bazelon has praised CMS for its active and crucial oversight to ensure that people with disabilities are not unjustly segregated and instead can live and receive services in their own homes and communities.

Read the Bazelon Center’s comments (submission ID 2367).

Read the December 16 CMS response to California’s proposal.

Maryland Continues to be Not Affordable for Many

Recent census data indicates that the cost of housing in the Baltimore area and the Maryland is increasing at a slower rate than the US. However, The increase of Maryland's housing costs is over 15% higher than the national average and a larger percentage of renters are cost burdened. The median Maryland renter pays around $1,600 a month in rent and utilities, about $100 more than the average Baltimore-area renter. Renters’ costs have increased 22.5% statewide and 24% in the Baltimore region compared with 32% nationally.

Nationally, the number of cost-burdened renter households hit yet another record high in 2023. In 2023, the number of renter households spending more than 30% of their incomes on rent and utilities was an all-time high of 22.6 million. A record-high 12.1 million severely burdened households spent over half of their incomes on housing costs. About half of all renter households were cost burdened in 2023. This rate was essentially unchanged compared to 2022, but rose 3.2 percentage points from pre-pandemic levels and 9.0 percentage points since 2001.

Nationally and within Maryland, renters are more likely to spend more than 30% of their income on housing. Statewide more than 46% of renters are cost burdened compared with a quarter of homeowners. In the Baltimore area (including Queen Anne’s County, Baltimore City, and the five surrounding counties) the same share of renters are cost burdened while the rate for mortgage holders is over a percentage point lower.

Baltimore City

The City has a mismatch between rental costs and the kind of rental units being constructed. Despite the growing unaffordability of housing in Maryland and especially the Baltimore area, luxury apartment buildings continue to be built. Since 2020, 80% newly constructed apartment buildings in Baltimore were luxury housing, according to real estate data firm the Costar Group. Most housing development worldwide is higher-end because of the higher profit potential for developers. 

Some areas of Baltimore have a particularly high cost burden for renters. Tract 907 in Baltimore’s Coldstream-Homestead-Montebello neighborhood, for example, 70% of households are cost burdened. Rental units are just over half of the housing stock. The Community Development Network of Maryland said incomes were not rising to meet the costs of rent, emphasizing the mismatch between the high number of luxury units versus what Baltimoreans can afford.

Anne Arundel County

In Arundel's tract 7305.11 in the Glen Burnie area, 67% of households are cost burdened. County Executive Steuart Pittman said the disparity was part of a “housing crisis.” “Affordability is more important than just supply,” Pittman said. “The affordability problem doesn’t get any better when all you build is luxury housing.”

Current housing developments across the county are not required to have affordable housing, but new projects will be. Under the Housing Attainability Act, becoming effective in July, new housing developments over 20 units will be required to have 15% of its units for affordable rentals and 10% for affordable homes for sale.

Howard County

Maryland’s most expensive jurisdiction for renters and mortgage holders, Howard - where 28% of housing units are rented - has the largest affordability gap between homeowners and renters. Some 44% of County renters were cost burdened compared to 20% of homeowners. The median rent in the county is $2,040 a month, while median monthly housing costs for homeowners was $2,950.

The County has recently made investments to stabilize the housing situation in the area, such as $2 million invested to subsidize rentals and security deposit guarantees for the families of county students experiencing homelessness. The County’s Moderate Income Housing Unit Program requires a percentage of housing built to be affordable to households of moderate income - with moderate income level defined as “household income less than 80% of the Howard County median income (AMI) for units for sale and household income less than 60% of the Howard County median income for rental units."

Read the December 12, 2024 Baltimore Sun article.

BOOK REVIEW: "The Black Butterfly: The Harmful Politics of Race and Space in America" Examines Baltimore's Segregation

The Black Butterfly: The Harmful Politics of Race and Space in America by Lawrence T. Brown. Johns Hopkins University Press, 2022. 384 pages. Paperback. $19.95.

This best-selling book looks at how American cities can promote racial equity, end redlining, and reverse the damaging health- and wealth-related effects of segregation. It was the winner of the IPPY Book Award Current Events II by the Independent Publisher, and a Finalist for the Pattis Family Foundation Global Cities by the Chicago Council on Global Affairs.

Amazon.com's description:

"The world gasped in April 2015 as Baltimore erupted and Black Lives Matter activists, incensed by Freddie Gray's brutal death in police custody, shut down highways and marched on city streets. In The Black Butterfly - a reference to the fact that Baltimore's majority-Black population spreads out like a butterfly's wings on both sides of the coveted strip of real estate running down the center of the city - Lawrence T. Brown reveals that ongoing historical trauma caused by a combination of policies, practices, systems, and budgets is at the root of uprisings and crises in hypersegregated cities around the country.

Putting Baltimore under a microscope, Brown looks closely at the causes of segregation, many of which exist in current legislation and regulatory policy despite the common belief that overtly racist policies are a thing of the past. Drawing on social science research, policy analysis, and archival materials, Brown reveals the long history of racial segregation's impact on health, from toxic pollution to police brutality. Beginning with an analysis of the current political moment, Brown delves into how Baltimore's history influenced actions in sister cities such as St. Louis and Cleveland, as well as Baltimore's adoption of increasingly oppressive techniques from cities such as Chicago. But there is reason to hope. Throughout the book, Brown offers a clear five-step plan for activists, nonprofits, and public officials to achieve racial equity. Not content to simply describe and decry urban problems, Brown offers up a wide range of innovative solutions to help heal and restore redlined Black neighborhoods, including municipal reparations. Persuasively arguing that, since urban apartheid was intentionally erected, it can be intentionally dismantled, The Black Butterfly demonstrates that America cannot reflect that Black lives matter until we see how Black neighborhoods matter."

Go to The Black Butterfly: The Harmful Politics of Race and Space in America book's website.

Listen to a 2020 America Walks interview/webinar with Lawrence T. Brown.

Book Review: "Sixty Miles Upriver: Gentrification and Race in a Small American City"

Sixty Miles Upriver: Gentrification and Race in a Small American City by Richard E. Ocejo. Princeton University Press, 2024. 288 pages. Hardcover. $29.95.

This book examines the effect on racial and income balance, gentrification, and social change in Newburgh, New York, of an influx of wealthier remote workers from NYC and its suburbs. The City's population is now about 50% Hispanic. To the author: "This demographic shift has made the city more primed for gentrification, which rarely happens in racially homogenous places. The Black population in Newburgh was previously too high to attract white gentrifiers, but the influx of Hispanic migrants changed the demographic mix, creating a more favorable environment for white middle-class newcomers and shaping Newburgh’s current identity."

As the author says about his book during an interview published in the local newspaper The Highlands Current: "At the heart of my book is: What do we owe to the communities that we move to when we’re newcomers? What obligations do we have to neighbors who have been calling this place home for much longer than we have? Do we disrupt or enhance?"

From Amazon.com's description:

"Newburgh is a small postindustrial city of 28,000 located sixty miles north of New York City. Like many other similarly sized cities across America, it has been beset with poverty and crime after decades of decline, with few opportunities for its predominantly minority residents. Sixty Miles Upriver tells the story of how Newburgh started gentrifying, describing what happens when White creative professionals seek out racially diverse and working-class communities, and revealing how gentrification is increasingly happening outside large city centers in places where it unfolds in new ways.

As New York City’s housing market becomes too expensive for even the middle class, many urbanites are bypassing the suburbs and moving to smaller cities like Newburgh, where housing is affordable and historic. Richard Ocejo takes readers into the lives of these newcomers, examining the different ways they navigate racial difference and inequality among Newburgh’s much less privileged local residents, and showing how stakeholders in the city’s revitalization reframe themselves and gentrification to cast the displacement they cause to minority groups in a positive light. An intimate exploration of the moral dilemma at the heart of gentrification, Sixty Miles Upriver explains how progressive White gentrifiers justify controversial urban changes as morally good, and how their actions carry profound and lasting consequences for vulnerable residents of color."

Read the November 1, 2024 The Highlands Current interview.

Read the May 17, 2024 interview in Chronogram: The River.

Book Review: "Before Gentrification: The Creation of DC's Racial Wealth Gap"

Before Gentrification: The Creation of DC's Racial Wealth Gap by Tanya Maria Golash-Boza. University of California Press, 2023. 311 pages. Paperback. $27.95.

Amazon.com's description: 

"Before Gentrification shows how a century of redlining, disinvestment, and the War on Drugs wreaked devastation on Black people and paved the way for gentrification in Washington, DC. Golash-Boza tracks the cycles of state abandonment and punishment that have shaped the city, revealing how policies and policing work to displace and decimate the Black middle class.

Through the stories of those who have lost their homes and livelihoods, she explores how DC's "troubling history makes clear that the choice to use prisons and policing to solve problems faced by Black communities in the twentieth century—instead of investing in schools, community centers, social services, health care, and violence prevention—is what made gentrification possible in the twenty-first. Before Gentrification unveils a pattern of anti-Blackness and racial capitalism in DC that has implications for all US cities."

This book is a personal project: as Golash-Boza states, “I have a personal investment in understanding how and why my neighborhood became plagued by violence, why so many of my childhood friends were murdered, why a generation of Black boys and men was put behind bars, and why so few of my childhood friends can afford to live in the neighborhood where we were raised” (p. 24). 

Regarding the book's reception, Golash-Boza posted in her Twitter (X) account: "I just read the first published review of Before Gentrification and it's a good reminder my book is not for everyone. The book clearly generates a different response in different readers - and that's fine. So far, the audience I most wanted to reach has responded positively."

Read the abstract of the book review in the December 2024 Social Forces. 

Read the December 2023 Twitter (X) post.

New Book "Slow and Sudden Violence" Treats Baltimore's Real Estate History

Derek Hyra, Slow and Sudden Violence: Why and When Uprisings Occur. University of California Press, 2024. 365 pages. Paperback. $29.95.

To Hyra in his new book, "equitable development involving residents of affected communities is essential to avoid continual displacement, increasing segregation, and social unrest." The Amazon.com description: 

"In Slow and Sudden Violence, Derek Hyra links police violence to an ongoing cycle of racial and spatial urban redevelopment repression. By delving into the real estate histories of St. Louis and Baltimore, he shows how housing and community development policies advance neighborhood inequality by segregating, gentrifying, and displacing Black communities. Repeated decisions to “upgrade” the urban fabric and uproot low-income Black populations have resulted in pockets of poverty inhabited by people experiencing displacement trauma and police surveillance. These interconnected sets of divestments and accumulated frustrations have contributed to eruptions of violence in response to tragic, unjust police killings. To confront American unrest, Hyra urges that we end racialized policing, stop Black community destruction and displacement, and reduce neighborhood inequality."

Hyra is Professor of Public Administration and Policy and founding director of the Metropolitan Policy Center at American University.

Read the December 12, 2024 NCRC article.

CFPB Sues Comerica Bank for Systematically Failing Disabled and Older Americans

The Consumer Financial Protection Bureau (CFPB) has sued Comerica Bank for systematically failing its 3.4 million Direct Express cardholders - disabled and older Americans who receive Social Security and other federal benefits. The bank deliberately disconnected 24 million customer service calls, impeding cardholders from exercising their rights under the law, charged illegal ATM fees to over 1 million cardholders, and mishandled fraud complaints while providing federal benefits through the Direct Express prepaid debit card program. The CFPB is asking the court to order Comerica to stop these practices, provide refunds to affected customers, and pay civil penalties to the CFPB's victim relief fund.

Comerica Bank is a subsidiary of Comerica Inc. (NYSE: CMA), among the 25 largest bank holding companies in the U.S. Incorporated in Delaware, it is headquartered in Texas. Comerica reported total assets of more than $84 billion and total deposits of over $71 billion. Since 2008, the U.S. Department of Treasury has contracted with Comerica Bank to administer the Direct Express program, in which 3.4 million federal beneficiaries receive their monthly benefits payments through prepaid debit cards. Direct Express is a prepaid card that beneficiaries can use to pay for groceries, gas, and other expenses.  

Comerica is in charge of customer service for the millions of Americans using Direct Express, many of whom are unbanked. Rather than ensuring that there was sufficient customer service to handle calls from the benefits recipients, Comerica instead boosted its bottom line. When people had problems with their accounts, it was often impossible to talk to someone for help. 

The CFPB’s investigation found that Comerica failed to ensure sufficient staff and even intentionally disconnected more than 24 million calls. The CFPB alleges that Comerica harmed its customers by:

• Deliberately disconnecting customer service calls: Comerica’s vendors intentionally dropped over 24 million calls from customers before they could reach a representative. Customers whose calls were not dropped were routinely forced to endure excessively long wait times - often more than several hours - to speak with a representative to get help with unauthorized transactions, charge disputes, and lost or stolen cards.
• Charging consumers illegal ATM fees: Over one million Direct Express cardholders were charged ATM fees to access their government benefits in situations where they were legally entitled to free withdrawals.
• Misleading fraud victims: When consumers contacted Comerica alleging they had been fraudulently enrolled into the Direct Express program, the bank’s vendors frequently advised the consumers that “no error occurred” although the bank had determined that there was, in fact, enrollment fraud.
• Imposing illegal terms of service on consumers seeking to stop payments: Comerica led its consumers to agree to waive their consumer protections by requiring cardholders to contact and request merchants to stop pre-authorized payment transfers from their account in situations where the law in fact required the bank to stop the transfers itself.
• Failing to investigate account problems: Under federal law, when a customer notifies a bank about an incorrect or potentially fraudulent charge on their account, the bank must take steps to investigate the error within a specified time period. The CFPB’s investigation found that Comerica failed to meet this requirement more than 20,000 times. When they did investigate, they frequently provided vague and confusing findings or blew off customers altogether.
• Forcing consumers to close accounts, which often resulted in additional fees: The bank’s vendors required thousands of cardholders to close their accounts to stop a preauthorized payment, resulting in consumers incurring additional fees to expedite receipt of their new debit cards to regain access to their government benefits.

Under the Consumer Financial Protection Act, the CFPB has the authority to take action against institutions violating consumer financial protection laws, including engaging in unfair, deceptive, or abusive acts and practices. The CFPB’s lawsuit seeks to stop Comerica’s unlawful conduct, to provide redress for harmed borrowers, and the imposition of a civil money penalty, which would be paid into the CFPB’s victims relief fund. Read today’s complaint.

Consumers can submit complaints about financial products and services by visiting the CFPB’s website or by calling (855) 411-CFPB (2372).

Employees who believe their company has violated federal consumer financial protection laws are encouraged to send information about what they know to whistleblower@cfpb.gov. To learn more about reporting potential industry misconduct, visit the CFPB’s website.

The Consumer Financial Protection Bureau is a 21st century agency that implements and enforces Federal consumer financial law and ensures that markets for consumer financial products are fair, transparent, and competitive. For more information, visit www.consumerfinance.gov.

Read the December 6, 2024 CFPB article.

Maryland Department of Housing and Community Development Publishes Just Communities Baseline Report

The Maryland Department of Housing and Community Development (MDHCD) has just published a baseline report from its Division of Just Communities. The report is the first formal publication of the new division. The report contains the mission and vision of the Division, information on racial disparities in Maryland housing and neighborhood conditions, and the current and ongoing work of the Department to address inequities.

The Just Communities baseline report:

• Defines the new Division’s scope to both internal and external stakeholders;
• Demonstrates the Division’s strong understanding of Maryland housing policy’s historic wrongs;
• Celebrates ongoing initiatives that can advance racial equity; and
• Introduces the Department’s Just Communities measurement strategy.

To read the full baseline report, click here.

The Department’s Division of Just Communities was created in 2023 to prioritize resources in areas with historical disinvestment to address the wrongs of the past. The Division is working to build and strengthen partnerships in communities with economic and housing trends that indicate a need for reinvestment.

Under the leadership of Assistant Secretary Cat Goughnour, the Division represents a new and focused effort by MDHCD and the State of Maryland to help reverse decades of exclusionary policies, opening pathways to opportunity in minoritized communities that have been previously denied them, and ensuring that no Marylander is left behind.

The Division will assist in the implementation of the Just Communities Act, which was signed into law by Governor Wes Moore during the 2024 Legislative Session. Effective July 1, 2024, this Act authorizes the governor, on recommendation by the DHCD Secretary, to designate areas as Just Communities based on specific criteria including a history of redlining, exclusionary zoning, high imprisonment rates, and unequal exposure to environmental or health hazards.

The Just Communities Act is part of MDHCD’s Turning the Key campaign, designed to raise awareness of the state’s efforts to address the housing unit shortage and unlock Maryland’s potential during the 2024 Legislative Session. The campaign encourages Marylanders to be part of the solution and communicates information on the implementation of new laws, including the Just Communities Act. 

To subscribe for updates about the Division of Just Communities, go to dhcd.maryland.gov/subscribe.

For more information about the Maryland Department of Housing and Community Development’s Division of Just Communities, visit dhcd.maryland.gov.

Read the November 26, 2024 MDHCD release.