Letters to Regulators
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.
AFR submitted a comment letter to the Financial Stability Oversight Council supporting the FSOC’s engagement in asset management activities.
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.”
“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.”
“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.”
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.
AFR and five other consumer advocacy organizations, sent a letter to SEC Chair Mary Jo White detailing key investor protections that the SEC has failed to take, and urging Chair White to act on them.
AFR and 9 other organizations sent a letter to Chair Mary Jo White expressing concern over the exclusion of Professor Joseph Stiglitz from the SEC Market Structure Advisory Committee. The letter urges the SEC to reconsider, or to provide more detail regarding how it arrived to its decision.