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Letters to Regulators

Joint Letter: CFPB Moves Forward on Nonbank Auto Lending
December 8, 2014 – 10:46 am

“Supervision of nonbank auto financial institutions will bring much-needed attention to otherwise
lightly-regulated companies, will ensure compliance with consumer financial laws, and will
ensure that auto financing by banks, already subject to CFPB supervision, is not at a competitive
disadvantage.”

AFR Letter: Mandatory Margin Requirements Needed for Uncleared Swaps
November 25, 2014 – 6:03 pm

“Mandatory margin requires participants in the swaps market to take full account of the risks of their derivatives transactions and provide some level of advance provisioning for such risks. The availability of properly segregated margin is clearly of enormous value in case of the default of a swaps counterparty.”

AFR Letter: CFTC and SEC Must Act Against Derivatives “De-Guaranteeing” Ploy
November 25, 2014 – 2:01 pm

“On behalf of Americans for Financial Reform (AFR), we write today to ask you to ensure appropriate regulatory oversight of derivatives transactions conducted through foreign subsidiaries of multinational Wall Street banks. In particular, we urge you to prevent the inappropriate classification of such derivatives as ‘non-guaranteed’ by the parent company, a classification which could exempt them from numerous critical derivatives regulations.”

AFR Joins More than 200 Other Groups in Urging FHFA Director Mel Watt to Reverse Fannie-Freddie Policy on Principal Reduction
November 6, 2014 – 10:00 am

Mel Watt is being urged again to end the policy of prohibiting mortgage modifications that reduce the balance of principal. In a joint letter delivered today, more than 200 housing, community, labor, civil rights and consumer groups call on Watt to reverse the Federal Housing Finance Agency’s longstanding ban on principal reduction – a policy put in place by his predecessor.

AFR and more than 450 Groups Urge CFPB to Stop the Payday loan Debt Trap
October 23, 2014 – 1:09 pm

AFR was joined by 464 civil rights, consumer, labor, faith and community organizations from all 50 states in a letter urging the CFPB to put in place strong rules that will end abusive practices in ‘quick fix’ consumer lending such as payday, auto-title and installment loans.

AFR and More Than 50 U.S. and International Groups Warn that TTIP Could Undermine Financial Reform
October 1, 2014 – 10:03 am

In a letter to U.S. and EU trade negotiators and finance ministers, more than 50 civil society groups on both sides of the Atlantic have come together to warn that the Transatlantic Trade and Investment Partnership (TTIP) currently under discussion could undermine new financial regulations and potentially create significant risks to the global financial system, as well as to investors and consumers.

AFR and 47 Organizations Support CFPB’s Proposal to Publish Consumer Complaint Details
September 19, 2014 – 7:52 am

AFR joined 47 organizations in supporting the CFPB’s work to make its complaint database public and accessible by consumers. This will help consumers make more informed decisions about how to choose the best products and services for their needs, and how to protect themselves from problems.

AFR Calls for Restrictions on Wall Street Executive Pay and Bonuses
September 18, 2014 – 10:32 am

AFR submitted a comment letter to federal regulators urging that they impose strong restrictions on Wall Street executive pay and bonuses to ensure that they do not create incentives to take inappropriate short-term risks. This should be made a critical priority, given the role of pay in creating the incentives that led to the 2008 financial crisis.