Letters to Regulators
AFR sent a letter to regulators emphasizing the lessons from the Senate Permanent Subcommittee on Investigations (PSI) report on the London Whale.
AFR submitted a comment letter to the CFPB supporting their proposed guidance clarifying the relationship of their servicing rules to stronger state laws. The letter also makes suggestions for improvement.
AFR joined more than 45 organizations in submitting a comment letter to the OCC and the FDIC supporting their proposed guidance on bank payday lending. The letter praises their proposal, and adds some additional steps that we believe would be beneficial to curbing the use of payday loans.
AFR joined public interest groups in weighing in on the CFPB’s proposal defining larger market participants for student loan servicing.
AFR submitted a comment letter supporting the proposed rules by the Board of Governors of the Federal Reserve System that set out enhanced prudential standards for foreign banking organizations and foreign non-bank financial companies.