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Letters to Regulators

Joint Letter: AFR, 163 Groups Call for Strong CFPB Action Against Forced Arbitration
April 28, 2016 – 8:57 am

“Yesterday, 164 organizations that advocate on behalf of consumers, students, civil rights, labor, small business, and more, sent a letter to the Consumer Financial Protection Bureau (CFPB), urging the agency to use its Congressional authority to restrict forced arbitration – the abusive practice in which corporations bury “ripoff clauses” in the fine print of take-it-or-leave-it contracts to block consumers from challenging hidden fees, fraud, and other illegal behavior in court.”

Letter to Regulators: AFR Joins Consumer Organizations in Commenting to the CFPB on Rural Creditors Rule
April 27, 2016 – 6:18 pm

“…the Consumer Financial Protection Bureau (the “Bureau”) published an interim final rule that redefines the small creditors serving rural and underserved areas who are exempt from certain consumer protections in Regulation Z. The interim final rule dramatically increases the number of lenders who qualify for this exemption. “

Letter to Regulators: AFR, 10 Orgs Urge Treasury, FinCEN to Complete the Anti-Money Laundering Rule for Asset Managers
April 4, 2016 – 12:08 pm

“In this last year of the Obama Administration, this proposed rule deserves priority attention for strengthening a key U.S. defense against money laundering that furthers terrorism, drug trafficking, organized crime, and tax evasion. It would close a major, decade-old gap that has allowed hedge funds, private equity funds, and other big investment firms to accept substantial funds with no questions asked, to facilitate the transfer of offshore funds into the United States without determining their source, and to witness troubling transactions with no legal obligation to report them.”

Letter to Regulators: AFR Supports SEC Proposal to Restrict Derivatives Use at Mutual Funds
March 30, 2016 – 12:51 pm

“… for many years the SEC did not sufficiently address the ways in which Investment Company Act restrictions can be violated through the use of derivatives. The SEC’s basic approach to derivatives risk at funds was set out in a series of releases and no-action letters between 1979 and the late 1980s. The fundamental approach adopted at that time was based on ‘offsetting’ or ‘coverage’ – that is, if a fund segregates assets deemed sufficient to ‘cover’ a derivatives risk, or an offsetting derivatives exposure, then derivatives usage would not violate ’40 Act limitations.”

Letter to Regulators: Regulators Must Not Weaken Dodd-Frank Regulations in the Regulatory Review Process
March 24, 2016 – 2:44 pm

“On behalf of Americans for Financial Reform, we are writing with regard to your current review of bank safety and soundness rules under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA) Notice #4 (December 23, 2015)… Reviewing these rules before they are finalized and while the process of implementation is still ongoing also carries the risk that the burden of implementation will be mistaken for the permanent effects of the rule.”

Letter to Regulators: Doing Better by Mortgage Applicants Who Are Not Fluent in English
March 24, 2016 – 10:45 am

“Allowing mortgage applicants to choose in which language they are most comfortable in communicating addresses a major problem of lenders and servicers working with limited English proficiency (LEP) populations and collecting this information through the URLA is the most comprehensive way to do so, because every mortgage borrower fills one out.”

Letter to Regulators: AFR Urges Federal Reserve and FDIC to Take Opportunity to End Too Big to Fail
March 22, 2016 – 11:38 am

“AFR sent a letter to banking regulators today concerning their review of bank resolution plans. The Dodd-Frank Act requires regulators to review these plans to ensure that major banks are no longer ‘too big to fail’ – that they can go through a conventional (Chapter 11) private bankruptcy in an orderly manner, without creating substantial economic disruption. “

Letter to Regulators: AFR Calls for Tougher Automated Trading Rules
March 18, 2016 – 12:24 pm

“[T]he proposed Reg AT is long overdue. At the same time, however, the self-regulatory approach taken here falls far short of a clear set of limits on the most dangerous and predatory practices made possible by automated trading technology.”