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Letters to Regulators

AFR Comment: Don’t Delay the Fiduciary Rule, Don’t Try to Kill It Either
September 15, 2017 – 10:33 am

The Department of Labor should simply let the fiduciary rule, as written, take full effect. The effort to delay is nothing but an effort to buy time for creating a rationale to roll back the rule, and an abuse of a regulatory process set down in law. Enough.

Letter to Regulator: AFR, 18 Organizations Call for Comprehensive Data on Small Business Lending
September 14, 2017 – 5:55 pm

We call on the Bureau: to require reporting on the full breadth of small business lending; to capture important data about loans applied for and made; and to complete the rulemaking and begin collection of these data expeditiously.

Letter to Regulator: AFR asks Fed to protect consumers in check forgery disputes
August 1, 2017 – 4:38 pm

“We support the proposed rule but urge the Board to clarify that the presumption be limited to disputes between banks and recommend the Board require banks to maintain original checks for a specified period of time.”

Letter to Regulator: AFR, 8 organizations provide detailed recommendations to FHFA to improve language access in the mortgage industry
August 1, 2017 – 4:10 pm

“The burden of interpreting financial services jargon and communicating with lenders and servicers should not rest solely on borrowers. . . . Expanding access to language services throughout the mortgage process would begin to equalize a system that currently undermines the ability of LEP borrowers to understand the complexities of their future homeownership prospects and to protect their home after purchasing it.”

Letter to Regulator: AFR, 86 organizations call for FHFA to make mortgages more accessible to people with limited English proficiency
August 1, 2017 – 4:01 pm

“As dominant actors in the mortgage industry with a statutory duty to facilitate underserved communities’ access to homeownership, we welcome the FHFA, Freddie Mac, and Fannie Mae’s consideration of steps to expand access to the mortgage market.”

Letter to Regulators: AFR Opposes SoFi’s Deposit Insurance Application
July 19, 2017 – 12:15 pm

“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”

Letter to Regulators: AFR Calls on the Dept of ED to Enforce, Not Dismantle, Borrower Defense and Gainful Employment
July 12, 2017 – 5:39 pm

Americans for Financial Reform submitted comments to the Department of Education in strong opposition to any delay to or re-opening of the Borrower Defense to Repayment and Gainful Employment regulations. The Department of Education (the “Department”) has already conduced the arduous process of negotiated rulemaking on both of these rules, where all constituencies were able to weigh in. Establishing new negotiated rulemakings on these rules is a waste of taxpayer money and government resources.

Letter to Regulators: AFR Calls on CFTC To Strengthen Risk Controls for Derivatives Dealers
May 16, 2017 – 2:04 pm

The full letter is linked below:
Americans for Financial Reform Comment Swaps Entity Capital and Liquidity Requirements