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Letters to Regulators

Joint Letter: 25 Organizations Write Dept of ED on Evaluating Undue Hardship Claims in Student Loan Bankruptcy
May 24, 2018 – 3:33 pm

AFR was among 25 organizations that signed-on to comments by the National Consumer Law Center on evaluating undue hardship claims in student loan bankruptcy. You can view or download the PDF here.

Letters to Regulators: AFR opposed roll back of transparency disclosures to investors in SEC proposed rule “Investment Company Liquidity Disclosures.”
May 22, 2018 – 12:03 pm

AFR commented on the roll back of transparency disclosures to investors in the SEC proposed rule “Investment Company Liquidity Disclosures.”

Joint Letter: 8 Organizations Warn Regulators Against Bank Payday Loans and Rent-a-Bank Arrangements
May 15, 2018 – 6:25 pm

“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”

Joint Letter to CFPB: An Inquiry Process Weighted in Industry’s Favor
April 30, 2018 – 9:35 am

“The RFIs pose questions that are almost entirely from an industry perspective and are insufficiently specific to elicit meaningful comment. The RFIs hint at changes desired by industry without providing enough detail to inform members of the public who do not have experience with the internal workings of the Bureau or the implications of the questions. This process weighted in industry’s favor is not consistent with the CFPB mandate to focus on consumer protection.”

Letter to Regulators: AFR urges the Dept of ED not to create barriers to emergency relief
April 4, 2018 – 7:26 pm

Americans for Financial Reform wrote to the Department of Education to voice concerns with two applications they have proposed for higher education institutions seeking access to emergency relief funds. In addition to creating barriers to accessing the funds, the forms are not available in Spanish, which will preclude potential applicants in Puerto Rico from accessing needed funds.

Letters to Regulators: AFR submitted a comment on new Federal Reserve rating system for large institutions
February 16, 2018 – 10:10 am

AFR sent a comment letter to the Federal Reserve Board on the proposed new rating system for supervision of large financial institutions.

Letter to Regulators: AFR Calls on Federal Reserve to Strengthen Bank Stress Tests
February 2, 2018 – 1:00 pm

AFR sent the below letter to the Federal Reserve commenting on a package of proposals for stress test transparency
AFR Comment on Stress Test Proposal Package