Category Archives: Education Fund

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Letters to Regulators: Comment Letter to OMB on Uniform Guidance Relating to Stock Buybacks and Executive Comepensation

AFREF and the Institute for Policy Studies, Global Economy Project led a comment letter to the Office of Management and Budget (OMB) about its uniform guidance, which sets the boundaries around the types of strings states and localities are allowed to attach when they disburse federal funds.  This comment letter argues state and local governments should be allowed to give preferential treatment to bidders that commit to make productive investments in their companies and refrain from stock buybacks and excessive executive compensation.

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Remarks: Written Remarks Regarding Digital Assets Policy Frameworks – Areas for MRAC Review

AFREF and Demand Progress Education Fund attended a meeting of the Market Risk Advisory Committee for the Commodity Futures Trading Commission. There, AFREF/DPEF staff gave remarks on digital assets, including recommendations to the Committee regarding research and analysis into proper regulatory oversight of the digital assets sector. Recommendations included research into cybersecurity risks associated with crypto platforms and crypto derivatives, as well as a review of due diligence processes conducted by the CFTC and other regulators when CFTC registered entities involved in digital assets are acquired by another firm.

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Letters to Regulators: Letters to the IRS and Treasury and the CFPB on Medical Debt

 AFREF joined two letters – one to the Internal Revenue Service (IRS) and Department of Treasury, and one to the Consumer Financial Protection Bureau (CFPB) – urging the Biden-Harris Administration to do more to relieve medical debt for tens of millions of people. The letters, signed by more than 60 organizations, include specific executive actions the administration can take to address medical debt.

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Letters to Regulators: Letter to OSTP Raising Concerns about Limits of Blockchain Technology

AFREF and Demand Progress Education Fund submitted comments to the Office of Science and Technology Policy (OSTP) in response to the agency’s request for information regarding the risks, limitations and purported benefits of blockchain technology (including regarding central bank digital currencies), to help inform the government’s research and development agenda on blockchain. The submission raised concerns about the technological limits and risks of blockchain as used for both financial and non-financial applications, as well as a variety of risks, and urged the OSTP to take a more balanced and sober look at blockchain in view of these limitations.

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Letters to Regulators: Letter From 29 Signers to the SEC on Passing Strong Final Rules on Private Fund Advisers to Protect Investors and the Financial System

AFREF led a letter with 29 signers to the Securities and Exchange Commission reiterating the important need to pass a strong set of final rules related to requiring private fund advisers to disclose a complete breakdown of fees/expenses, assumptions used to calculate returns, and the existence of side letters to investors.

The letter is also urging the SEC to finalize a strong set of rules related to requiring private fund advisers over a certain size to report more detailed information about their holdings confidentially to the SEC so that the SEC and other financial regulatory agencies have much greater insight into the risks in the $21 trillion private fund space where there is currently little visibility in order to better safeguard the financial system.

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Letters to Regulators: Letter to ED on IDR Proposed Rulemaking

AFREF joined a letter to the Dept. of Education applauding the Department for the significant positive impact its proposed changes to the IDR rules could have on student loan borrowers.  The proposed rule has the ability to substantially reduce monthly and lifetime payments for millions of borrowers, raise the threshold for protected non-discretionary income, lower the share of discretionary income borrowers have to pay, waive unpaid interest, and decrease time to cancellation.

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A book titled "Consumer Protection" on a desk with a gavel resting on top

Letters to Regulators: Letter to the FTC on Junk Fees

AFREF and partners led a letter to the FTC urging it to use its rulemaking authority to protect American consumers from junk fees and put money back into our pockets. Millions of consumers have expressed outrage at the imposition of service fees for live event tickets, “amenity” or “resort” fees charged by hotels, endless surprise rental car fees, hidden internet and cell phone charges, junk fees in the financial sector, and more. The federal government has taken a holistic approach to this problem, including the White House Competition Council, the Consumer Financial Protection Bureau (CFPB), the Department of Transportation (DOT) and now the FTC. 

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SEC Building

Letters to Regulators: Letter to the SEC on Standards for Covered Clearing Agencies for U.S. Treasury Securities and Application of the Broker-Dealer Customer Protection Rule With Respect to U.S. Treasury Securities Fund Advisers

AFREF submitted a comment to the Securities and Exchange Commission (SEC) on December 27th supporting its proposals that would centrally clear the $27 trillion U.S. Treasury market, one of the largest and most systemically important markets in the world. 

Shockingly, despite the Treasury market’s importance, no one regulator has complete visibility into this market and the SEC’s proposals move closer to implementing the Inter-Agency Working Group on Treasury Market Surveillance’s (IAWG) recommendations to give regulators such as the SEC and the Financial Stability Oversight Council (FSOC) greater visibility and oversight.  

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