Letters to Regulators
“After finally addressing the fee waiver tax abuse after all of these years, the least the IRS can do is to vigorously enforce the law for all open years. Anything less would accurately be described as a tax amnesty program for billionaires.”
“Given the extensive evidence of widespread fraud at Corinthian Colleges, we believe all current and former students deserve federal loan discharges. We are particularly concerned that students whose entitlement to federal loan discharges is crystal clear – those recently enrolled in the 30 Corinthian campuses that closed on Monday – are being given incomplete, incorrect, and harmful information about their options from Education Department staff as well as from schools that do not have these students’ best interests in mind. “
AFR provided comments to the Federal Reserve on a proposal to require more capital for the largest banks. While supporting the idea of additional capital for these banks, AFR’s comment criticized the level as too low.
AFR submitted a comment letter to the Financial Stability Oversight Council supporting the FSOC’s engagement in asset management activities.
At a CFPB hearing in Richmond, Va., AFR delivered a letter in which a remarkable array of civil rights, faith, economic justice, elder, community and civic organizations – 500 altogether, including groups from all 50 states – applaud the CFPB for its commitment to this issue and urge it to develop and implement regulations that finally put payday, car-title and other small-dollar lenders “on the same footing as other lenders, requiring them to play by the rules and make fair loans.”
“Few practices are as abusive, unfair, and deceptive as the widespread use of forced arbitration clauses in most consumer contracts, including credit cards, student loans, debt settlement, credit repair, auto financing, and payday loans. Forced arbitration funnels consumers into a private system set up by corporations to protect and hide harmful and unlawful corporate behavior.”
“While the [proposed] rules are generally strong, we offer several suggestions below for strengthening the rules and closing loopholes. In particular, the CFPB should ban all overdraft fees; apply credit card protections to all credit transferred to a linked prepaid card; and limit fees before account opening and beyond the first year. We also urge the CFPB to require prepaid card funds to be held in accounts protected by deposit insurance and to adopt stronger rules to prevent coercive use of payroll, public benefit, student, released prisoner and other prepaid cards.”
AFR submitted comments to the CFPB on the agency’s proposed amendments to its mortgage servicing regulations. AFR appreciates the CFPB’s attention to dealing with continuing problems facing borrowers seeking loan modifications, supports proposed steps to address them, and urges further changes to do so more effectively.