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.
