The proposed rules weaken a compliance system that needs to be strengthened, introduce new loopholes and add confusion and inconsistency, all while failing to address the real changes needed to modernize CRA to respond to changes in our country’s demographics and changes in the structure of the banking industry.
News Release: AFR Education Fund Statement: FDIC/OCC Proposal Would Weaken the Community Reinvestment Act
Contrary to the mission of CRA, the FDIC/OCC proposal makes it easier for banks to ignore the variety of credit needs in the communities they serve, and leave them further behind.
We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.
Support letter for the Protecting Your Credit Score Act of 2019
Under the rule, a borrower would have to sign a notice authorizing the lender to withdraw from the account after those two consecutive failures. “If I was smart, I would only sign that if there was money in there,” says Linda Jun, a policy counsel with Americans for Financial Reform, a regulatory and consumer protection coalition. “Aside from getting charged more for a negative balance, banks close bank accounts over this stuff, you could lose access to banking entirely.”
In The News: It’s Time for Congress to Do Something About the Economic Mess that Private Equity Giants Have Created (Business Insider)
Nobel laureate economist Joseph Stiglitz: “[A] recent study by groups including Americans for Financial Reform found that private-equity bankruptcies in the retail industry alone cost 600,000 jobs. One of those laid off, Giovanna De La Rosa, told of her experiences in this publication. The best outcome would be fewer bankruptcies, but when they happen, the welfare of workers needs to be at the top of the list, not at the bottom.”
AFR held a day-long convening of experts to discuss emerging issues in the SEC regulation of registered investment companies (mutual funds and Exchange Traded Funds that are registered under the 1940 Act).
Letter to the NCUA urging them to prioritize consumer compliance
In The News: Want To Make Payday Loans In States Where It’s Outlawed? Rent A Bank! (Talking Points Memo)
FDIC Chair Jelena McWilliams “is doing the bidding of loan sharks who have a decades-long history of trying to get around state consumer protection rules,” Americans for Financial Reform spokesperson Carter Dougherty observed. “And now a federal regulator is helping them do it.”
Rep. Rashida Tlaib (D-Mich.) introduced groundbreaking and essential legislation to repeal the deeply flawed Opportunity Zone tax break passed as part of the 2017 tax cut legislation. In addition to the basic problems with this tax break for the wealthy, multiple media exposés have already found that the rules have been bent to include parcels that benefitted high-rolling real estate investors, including those with ties to the Trump administration.