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Letters to Regulators

Letters to Regulators: AFR Education Fund sent a letter to the Federal Reserve urging regulators to reject misguided recommendations regarding the implementation of S.2155.
October 1, 2018 – 1:03 pm

October 1, 2018
Americans for Financial Reform Education Fund (AFR Education Fund), sent a letter to the Federal Reserve in response to the recent letter from Senator Perdue and others. The Perdue letter urges regulators to …

Letters to Regulators: AFR Education Fund submitted a letter to the SEC regarding proposed amendments to the Whistleblower Program rules
September 19, 2018 – 10:55 am

Americans for Financial Reform Education Fund sent a letter to the SEC regarding proposed amendments to the Commission’s Whistleblower Program rules. While we generally support a few of the proposed amendments, we are concerned that …

Joint Letter: 62 Orgs Urge ED to Reject Changes that Weaken Accountability
September 13, 2018 – 4:47 pm

Americans for Financial Reform Education Fund joined with 61 other organizations to tell the Department of Education that we are closely monitoring their ongoing efforts to recklessly deregulate higher education.
As 62 organizations and advocates for …

Joint Letter: 68 Orgs Call on Dept of ED to Preserve Gainful Employment Rule
September 13, 2018 – 4:39 pm

Americans for Financial Reform Education Fund joined with 67 other organizations working on behalf of students, consumers, vets, servicemembers, civil rights, & college access to urder Education Secretary Betsy Devos not to eliminate the gainful employment …

Letter to the Regulators: AFR Submits Comment on Borrower Defense NPRM
August 24, 2018 – 6:21 pm

“The Proposed Rule is a brazen attempt to dismantle more than 20 years of borrowers’ rights to a defense to repayment on their loans when schools break the law. This dismantling will do nothing more than unleash a new wave of waste, fraud and abuse. This country teaches people that education is a path to a better life. For far too many years, allowing Title IV funds to flow to institutions engaging in fraud has turned this dream into a nightmare for their students. If the Department continues down this path of dismantling the right to a borrower defense, its legacy will be condemning students to lives full of poverty, while allowing executives of predatory proprietary institutions to become wealthy at their expense.”

Letters to Regulators: AFR sent a letter to the U.S. Commodity Futures Trading Commission criticizing a new de minimis threshold proposal
August 14, 2018 – 9:33 am

The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC …

Joint Letter: SEC Broker Proposal Fails To Establish Strong Standard or Mitigate Conflicts
August 7, 2018 – 11:10 am

The rule’s most significant failing is that it does not establish a clear uniform best interest standard, one that is no less stringent than that found in the Investment Advisers’ Act, for all professionals who provide investment advice to retail clients. Instead, it adopts a weaker standard for broker-dealers that falls short of a true best interest standard and does not adequately address the conflicts of interest that too often are permitted to taint broker-dealers’ recommendations.

Letters to Regulators: AFR commented on Federal Reserve, OCC, FDIC proposed rule regarding the implementation of CECL accounting rules.
July 13, 2018 – 11:00 am

Americans for Financial Reform sent a letter to the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation commenting on a proposal …