On January 9, 2020, 29 organizations sent a letter to the Consumer Financial Protection Bureau regarding the importance of applying Truth in Lending Act protections to PACE loans.
We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.
Letter to the NCUA urging them to prioritize consumer compliance
Letters to Regulators: AFR Ed Fund sent a letter opposing proposal to exempt foreign derivative clearing organizations from registration with the CFTC.
View or download a PDF version of the full letter.
Letters to Regulators: Joint letter to the SEC urging Chairman Clayton to withdraw anti-investor guidance that would undermine independent audits of public companies.
View or download a PDF version of the letter. Consumer Federation of America AFL-CIO Better Markets Center for American Progress Americans for Financial Reform November 21, 2018 Dear Chairman Clayton: We are writing to express our grave concerns regarding PCAOB staff guidance on Rule 3526(b),
Letter to Regulators: AFR Ed Fund and Demand Progress Ed Fund urge the Federal Reserve Board to enact strong consumer protections into their FedNow system
The development of a real-time, ubiquitous payment system is an especially complex, expensive undertaking. Because of the scale of the endeavor, and its potential to impact the American public as a whole, we firmly believe the Board is the appropriate entity to establish a universal 21st century payments system.
Joint Letter: Letter to Federal Reserve Emphasizing Need for Strong Consumer Protections in Real Time Payment Systems
Coalition letter urging the Federal Reserve to build in strong consumer protections into the design of its new real-time payment system
Joint Letter: Letters to FDIC, OCC, Federal Reserve, Urging to Stop Banks from Helping Payday Lenders Evade State Interest Rate Limits
A coalition of 61 consumer, civil rights, and community groups today sent letters to three federal bank regulators urging them not to allow their banks to help payday lenders evade state interest rate limits.
The AFR Education Fund wrote to the FDIC urging them to maintain comprehensive disclosure requirements for securitizations that are backed by depository banks. The agency is proposing to exempt private offerings from these requirements. Most of the toxic mortgage securitizations sold prior to the financial crisis were private offerings.
The 45 undersigned consumer, housing, civil rights, labor, and community organizations write to express our strong opposition to the proposed changes to the disparate impact standard (“Proposed Rule”) as interpreted by the U.S. Department of Housing and Urban Development (“HUD”).