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Letters to Regulators

Letter to Regulators: New Jersey Investor Protection Rule Would Fill Regulatory Void
June 14, 2019 – 3:03 pm

Given the unfortunate demise of the Department of Labor (DOL) Fiduciary Rule and the glaring deficiencies in the Securities and Exchange Commission’s (SEC’s) Regulation Best Interest, we greatly appreciate states such as New Jersey that are willing to step in to fill the regulatory void by providing the protections investors need and expect.

Letter to Regulators: Letters to FDIC, OCC, and Fed Urging them to Prevent Bank Payday Loans
June 7, 2019 – 1:28 pm

Even within our broad coalition, it is exceedingly rare for so many organizations to come together and to speak with one voice. The tremendous outpouring of opposition to high-cost, short-term loans that put people in a cycle of debt, whether issued by banks or nonbanks, illustrates the importance of this issue to people across the country.

Letter to Regulators: Coalition Comment on Opportunity Zone Data Collection
June 3, 2019 – 10:13 am

24-Group Organizational letter on the need to collect data on Opportunity Zone tax break that could reduce affordable housing options, displacing lower-income families of color.

Letter to Regulators: AFR Education Fund Comment on Opportunity Zone Data Collection
June 3, 2019 – 10:07 am

AFR Education Fund comment on the need to collect data on Opportunity Zone tax break that could reduce affordable housing options, displacing lower-income families of color.

Letter to Regulators: Comprehensive Comment On CFPB’s Proposal To Repeal Payday Rule
May 17, 2019 – 5:04 pm

The Proposal—a plainly outcome-driven, 47-page exercise in grasping for straws—has offered no reasonable basis to rescind that Rule. Based on a distorted focus on the Rule’s “dramatic impacts” on lenders’ ability to engage in a predatory practice, rather than on the need to protect consumers, the Proposal claims that the evidence must somehow be “more robust.” If the Rule requires significant changes for payday and vehicle title lenders, it is because the harm to consumers is dramatic. The Bureau’s new approach would ignore its consumer protection mandate and require the agency to hesitate when consumer harm is the most severe.

Letter to Regulators: Stop The Debt Trap Short Letter on CFPB’s Proposal to Repeal Payday Rule
May 15, 2019 – 6:06 pm

We, the undersigned 429 civil rights, consumer, labor, faith, veterans, senior, business, and community organizations from 46 states plus the District of Columbia write to vehemently oppose the proposed rescission of the common sense ability-to-repay requirements of the Consumer Financial Protection Bureau (the Bureau)’s 2017 payday and vehicle title loan rule (“Ability-to-Repay Rule” or “Rule”).

Letters to Regulators: AFR Education Fund comment on FSOC’s proposed guidance weakening oversight of nonbank systemically important financial institutions
May 14, 2019 – 10:11 am

On May 13, 2019, Americans for Financial Reform Education Fund sent a letter to the Financial Stability Oversight Council warning about the dangers of weakening oversight of nonbank financial firms even if such a firm could impose a threat to financial stability.

Letters to Regulators: Coalition Letter to the CFPB on PACE financing
May 7, 2019 – 9:47 pm

On March 7, 2019, AFR Education Fund and 25 organizations submitted a letter to the Consumer Financial Protection Bureau on the need for strong consumer protections for Property Assessed Clean Energy (PACE) loans.
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