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Letters to Regulators

Letter to Regulators: AFR Opposes SoFi’s Deposit Insurance Application
July 19, 2017 – 12:15 pm

“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”

Letter to Regulators: AFR Calls on the Dept of ED to Enforce, Not Dismantle, Borrower Defense and Gainful Employment
July 12, 2017 – 5:39 pm

Americans for Financial Reform submitted comments to the Department of Education in strong opposition to any delay to or re-opening of the Borrower Defense to Repayment and Gainful Employment regulations. The Department of Education (the “Department”) has already conduced the arduous process of negotiated rulemaking on both of these rules, where all constituencies were able to weigh in. Establishing new negotiated rulemakings on these rules is a waste of taxpayer money and government resources.

Letter to Regulators: AFR Calls on CFTC To Strengthen Risk Controls for Derivatives Dealers
May 16, 2017 – 2:04 pm

The full letter is linked below:
Americans for Financial Reform Comment Swaps Entity Capital and Liquidity Requirements

Joint Letter: AFR Joins 15 Organizations Praising, Pressing CFPB on Discriminatory Credit Practices
May 5, 2017 – 10:21 am

“We welcome the CFPB’s update of Regulation B, which implements the ECOA, and have joined in the comprehensive comments filed by the National Community Reinvestment Coalition. More changes are needed to Regulation B, however, to give consumers stronger protections against discrimination in the credit marketplace.”

AFR, 29 Orgs Raise Concerns Over New Ownership of Predatory Colleges
May 4, 2017 – 10:03 am

AFR joined 29 other individuals and organizations representing students, consumers, veterans, servicemembers, and civil rights to send a letter to Education Secretary DeVos raising concerns around the questionable sale of EDMC to the Dream Center Foundation.

Letter to Regulators: AFR Calls on CFTC to Forcefully Regulate High-speed Automated Trading
May 2, 2017 – 11:28 am

“…We urged the Commission to be more aggressive in laying out structural reforms to the markets and more specific limits on dangerous automated trading practices. The current Supplemental NPRM does not change our basic assessment, as it maintains the basic framework of the 2015 NPRM, with no movement toward additional specificity in risk limits or risk control requirements or reduced discretion for market actors in designing and implementing risk controls…

Letter to the Regulators: AFR, 31 Orgs Support the CFPB’s Student Loan Servicer Data Collection
April 24, 2017 – 4:14 pm

AFR and 30 other organizations sent a sign-on letter to the Consumer Financial Protection Bureau in support of their proposed student loan servicing data collection initiative. Compiling such metrics and borrower outcomes would benefit market participants, federal and state agencies, policymakers, and borrowers. Obtaining a clearer view of the student loan market overall will help inform all market participants on how best to serve student loan borrowers.

Letter To Regulators: Department of Labor Must Not Weaken The Conflict of Interest Rule
April 18, 2017 – 9:47 am

“On behalf of Americans for Financial Reform, we are writing to express our support for the Department of Labor’s (DOL’s) conflict of interest rule or “Fiduciary Duty” rule and our strong opposition to eliminating or …