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Letters to Regulators

Letter to Regulator: AFR, 3 Organizations Call for Strong Guidance on “Management Fee Waiver”
May 11, 2015 – 2:58 pm

“After finally addressing the fee waiver tax abuse after all of these years, the least the IRS can do is to vigorously enforce the law for all open years. Anything less would accurately be described as a tax amnesty program for billionaires.”

Joint Letter: Corinthian Students Deserve Federal Loan Relief, Say AFR and 33 Cosigners
May 1, 2015 – 5:04 pm

“Given the extensive evidence of widespread fraud at Corinthian Colleges, we believe all current and former students deserve federal loan discharges. We are particularly concerned that students whose entitlement to federal loan discharges is crystal clear – those recently enrolled in the 30 Corinthian campuses that closed on Monday – are being given incomplete, incorrect, and harmful information about their options from Education Department staff as well as from schools that do not have these students’ best interests in mind. “

Letter to Regulator: AFR Comments to Federal Reserve Urging More Capital for Large Banks
April 3, 2015 – 10:35 am

AFR provided comments to the Federal Reserve on a proposal to require more capital for the largest banks. While supporting the idea of additional capital for these banks, AFR’s comment criticized the level as too low.

Letter to Regulator: AFR Comment to the FSOC on Regulation of Asset Managers
March 27, 2015 – 5:28 pm

AFR submitted a comment letter to the Financial Stability Oversight Council supporting the FSOC’s engagement in asset management activities.

Joint Letter: 500 Organizations Unite in Call for a Strong CFPB Payday Rule
March 26, 2015 – 11:10 am

At a CFPB hearing in Richmond, Va., AFR delivered a letter in which a remarkable array of civil rights, faith, economic justice, elder, community and civic organizations – 500 altogether, including groups from all 50 states – applaud the CFPB for its commitment to this issue and urge it to develop and implement regulations that finally put payday, car-title and other small-dollar lenders “on the same footing as other lenders, requiring them to play by the rules and make fair loans.”

Joint Letter: AFR and 105 State, Local and National Groups Call for an End to Forced Arbitration in Consumer Finance
March 24, 2015 – 6:41 pm

“Few practices are as abusive, unfair, and deceptive as the widespread use of forced arbitration clauses in most consumer contracts, including credit cards, student loans, debt settlement, credit repair, auto financing, and payday loans. Forced arbitration funnels consumers into a private system set up by corporations to protect and hide harmful and unlawful corporate behavior.”

Joint Letter: AFR Joins 44 Other Signers of Letter Urging CFPB Action to Make Prepaid Cards Safer
March 23, 2015 – 6:33 pm

“While the [proposed] rules are generally strong, we offer several suggestions below for strengthening the rules and closing loopholes. In particular, the CFPB should ban all overdraft fees; apply credit card protections to all credit transferred to a linked prepaid card; and limit fees before account opening and beyond the first year. We also urge the CFPB to require prepaid card funds to be held in accounts protected by deposit insurance and to adopt stronger rules to prevent coercive use of payroll, public benefit, student, released prisoner and other prepaid cards.”

Letter to Regulator: AFR Comment on CFPB Amendments to 2013 Mortgage Rules
March 17, 2015 – 9:53 am

AFR submitted comments to the CFPB on the agency’s proposed amendments to its mortgage servicing regulations. AFR appreciates the CFPB’s attention to dealing with continuing problems facing borrowers seeking loan modifications, supports proposed steps to address them, and urges further changes to do so more effectively.