Americans for Financial Reform Education Fund signed onto several letters opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.”
Americans for Financial Reform Education Fund signed onto a predatory lending letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it was inconsistent with the agency’s fundamental charges to ensure safety and soundness, consumer protection, fair lending, and the aims of the Community Reinvestment Act. The letter stated that the OCC did not have the authority to make such a proposal, and that it created an unmistakable and absolute conflict by pressuring banks to finance lenders whose models are driven by unaffordable lending.
Americans for Financial Reform Education Fund signed onto a comment letter, organized by Public Citizen, opposing the OCC’s proposed rule “Fair Access to Financial Services” due to climate concerns. The letter urged the OCC to withdraw the proposal on the basis that it required banks to serve every category of high-risk business, with the express goal of increasing bank lending to risky fossil fuel companies and other polluting sectors, and without regard for strategic or reputational risk. The letter stated that the OCC lacked the legal authority to enact this proposed rule, that banks are acting prudently to exit the fossil fuel industry because of growing climate risk to the sector, and that the OCC should instead scrutinize and curb banks’ involvement with high-emission activities.
Americans for Financial Reform Education Fund signed onto a housing letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it is a perversion of long-held anti-discrimination principles. The letter stated that the OCC appropriated civil rights language to protect market activities, drafted vague and unintelligible standards, undermined the ability of financial institutions to consider important facets of reputational risk in making investment and underwriting determinations, and provided a negligently inadequate 45-day comment period in the midst of the COVID crisis.
Americans for Financial Reform Education Fund signs onto two comment letters to the OCC about Oportun’s application for a national bank charter. The letters express several concerns about Oportun’s practices regarding debt collection, lending and Community Reinvestment Act compliance planning. They urge the OCC to condition Oportun’s charter upon substantial improvement of these practices.
AFR released recommendations for “Day One” policy actions by the Biden Administration in the areas of banking regulation, securities and markets regulation, and addressing systemic risk. These are actions that could be taken without a lengthy rulemaking and would make immediate progress toward a fairer
AFR released policy recommendations to strengthen consumer financial protections and work towards reversing the damage caused by systemic racism, and products and systems that amplify inequality.
Thank you for your strong commitment to opposing the Office of the Comptroller of the Currency (OCC)’s efforts to help tech companies dodge regulatory oversight, mix commerce and banking activities, and avoid compliance with consumer protection laws.
AFR released a recommended set of systemic reforms outlining steps to create a safe and just financial system. These include both reversing the deregulation of the Trump years and taking positive steps to create a far more secure and inclusive financial system. The full document
The regulator of the nation’s largest banks has finalized a rule that allows predatory lenders to do an end-run around state interest rate caps, exposing people to loans in excess of 100% APR that violate state rate limits. Merely by putting a bank’s name on the fine print of the paperwork, predatory lenders could claim that the loan is a bank loan exempt from state rate caps.