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Letters to Regulators

Letters to Regulators: AFR Education Fund letter to the SEC opposing cross-border rule proposal
July 23, 2019 – 11:54 am

On July 23, 2019, AFR Education Fund submitted a letter to the U.S. Securities and Exchange Commission (SEC) opposing a proposal that would create exemptions that would permit U.S. banks – and international banks active in the U.S. market – to do large-scale derivatives dealing in the U.S. without being designated as derivatives dealers under Dodd-Frank Act rules.

Letter to Regulators: Letter to Federal Reserve on Bank Ownership and Control
July 16, 2019 – 10:03 am

AFR wrote a letter to the Federal Reserve Board on a proposal that would liberalize the criteria the Board uses to determine control of a bank. The definition of “control” is critical as it determines whether entities with ownership and influence over banks will be designated as bank holding companies and subject to the appropriate regulation.

Letter to Regulators: Coalition Letter on FHA Single-Family Loan Sale Program
July 8, 2019 – 3:02 pm

FHA mortgages play a crucial role in providing and maintaining access to affordable and sustainable homeownership for low- and moderate-income families and communities of color. If the Loan Sale Program continues in its current unregulated form, FHA borrowers and their communities remain at risk of further harm from non-compliant servicers and private equity loan purchasers. It is crucial that HUD implement strong protections both before and after loans are sold to prevent needless borrower displacement and neighborhood instability.

Joint Letter: Letter to HUD on FHA Loan Sales
July 5, 2019 – 10:49 am

AFR Ed Fund and six other organizations submitted these comments in response to the Department of Housing and Urban Development (HUD)’s advance notice of proposed rulemaking (ANPR) on the FHA Single Family Loan Sale program.
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Letter to Regulators: Coalition Letter on IRS Opportunity Zone Rules
July 2, 2019 – 10:54 am

The proposed loophole-ridden rules let investors to reap tax benefits for investments outside of the Opportunity Zones, compounding the program’s tendency to invest in booming areas that drive up housing costs and displace lower-income residents of color.

Letter to Regulators: Comment to HUD on FHA Servicing Defect Taxonomy
June 28, 2019 – 2:07 pm

Developing clear and appropriate standards for the servicing taxonomy will help ensure that servicers are properly held accountable for non-compliance with FHA’s requirements. It promises to improve the quality of FHA servicing, which in turn will benefit homeowners and the Mutual Mortgage Insurance (MMI) fund. HUD must ensure that its taxonomy tool encompasses these loss mitigation regulations and allows for borrower input into servicer performance in order to truly gauge whether loss mitigation is working for neighborhoods and for the MMI fund.

Letter to Regulator: Petition to SEC Seeking Ban on Stock Buybacks and Strong Worker Protections
June 25, 2019 – 5:52 pm

Today, 19 groups sent a petition to the SEC urging the Commission to initiate a rulemaking to revise Rule 10b-18 to ban stock buybacks and protect workers.

Letters to Regulators: Americans for Financial Reform Education Fund letter opposing the FDIC relaxing the process of resolution planning for Insured Depository Institutions
June 24, 2019 – 1:27 pm

Americans for Financial Reform Education Fund raised concerns over weakening resolution planning requirements intended to prepare large bank holding companies for an orderly resolution in conventional bankruptcy without risk to financial stability and without any reliance on extraordinary public support of the failed bank or its counterparties.