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Letters to Regulators

Letter to Regulators: AFR Comment on Special Purpose National Bank Charters for Fintech Companies
January 17, 2017 – 5:35 pm

We along with more than 250 organizations separately submitted a letter urging the OCC to refrain from issuing charters to nondepository fintech lenders because doing so would enable the chartered entities to avoid state interest rate caps and other state consumer protection laws, as well as state oversight, thereby putting consumers and small businesses at risk.

Joint Letter to Regulators: More Than 250 Groups Urge OCC Not to Offer Fintech Charters
January 13, 2017 – 2:11 pm

“State laws often operate as the primary line of defense for consumers and small businesses; thus, the proposal puts them at great risk. The OCC must not undermine state rate caps. Interest rate caps are the simplest, most effective way to protect borrowers from unaffordable, high-rate loans and to align the interests of lenders and borrowers.”

Letter to Regulators: AFR Comments to CFTC on Improving Cross-Border Regulations of Derivatives
December 21, 2016 – 1:07 pm

We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.

AFR Statement: AFR Calls on SEC to Resist Industry Calls to Weaken Fund Derivatives Limits
December 15, 2016 – 5:58 pm

We are deeply concerned that the Investment Company Institute (ICI) Letter lays out a set of changes to the Proposed Rule which wold effectively negate the derivatives exposure limits in the rule and render them useless as a tool for controlling speculative leverage at registered funds, as is required by the 1940 Act. …This change would not simply modify the relative weighting of derivatives exposures, but would result in a massive increase in the absolute limit on derivatives risk exposure.

Joint Letter: AFR and AFL-CIO Oppose Weakening of Corporate Disclosures
November 7, 2016 – 12:16 pm

AFR joined with the AFL-CIO in calling on the Securities and Exchange Commission to revise its proposed rule so that “any changes to the Commission’s disclosure rules do not narrow the scope of information that is provided to investors.”

Letter to Regulator: Over 700 National, State and Community Organizations Call for a Strengthened Final Rule on Payday and Car Title Lending
October 7, 2016 – 1:56 pm

We, the undersigned 724 civil rights, consumer, labor, faith, veterans, seniors, business, and community organizations from all 50 states, write to urge that you ensure the current rulemaking concerning payday, car title, and high‐cost installment loans ends the debt trap. A strong rule must be free of loopholes that will allow predatory practices to continue.

Letter to Regulator: AFR comments to Federal Reserve on capital requirements for insurance companies
October 5, 2016 – 2:41 pm

Insurance companies played a significant role in the 2008 financial crisis, both directly and indirectly. American International Group (AIG), the world’s largest insurance group at the time, was at the epicenter of the crisis, and of course collapsed and required the largest government bailout in U.S. history.

Letter to Regulators: AFR Urges the CFPB to Restrict Forced Arbitration
August 23, 2016 – 9:53 am

“Americans for Financial Reform (“AFR”) appreciates this opportunity to comment on the above referenced proposed rule (the “Rule”) by the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) to restrict the use of forced arbitration clauses in consumer finance contracts. Forced arbitration is a system designed to leave consumers with no practical ability to enforce their most basic rights and protections.”