Search Results for: letters to regulators

Comments & Letters to Regulators

Letters to Regulators: Letter to the Department of Treasury’s Federal Insurance Office Urging the Swift Release of Climate Change and Insurance Affordability Data

AFREF and 36 partners led a letter urging the Department of Treasury’s Federal Insurance Office (FIO) to swiftly release the homeowner insurance data that the National Association of Insurance Commissioners collected from over 330 insurers representing over 80% of the property and casualty market while also urging FIO to swiftly release a robust report analyzing the data.

Letters to Regulators: NCUA Budget for 2025-2026 Should Dedicate Funding to Support Climate Financial Risk Mitigation and Climate Resilience Opportunities for Credit Unions & Their Members

Americans for Financial Reform Education Fund led and submitted a letter to the National Credit Union Administration (NCUA) on the agency’s draft 2025-2026 budget. It urges NCUA to appropriately dedicate funding to support credit unions on climate-related financial risk mitigation, climate resilience, and providing safe, equitable green lending for their members. The letter was endorsed by

Letters to Regulators: Letters to the FDIC Regarding the Change in Bank Control Act

The Americans for Financial Reform Education Fund (AFREF), along with 37 labor unions, investors, and advocacy organizations, submitted a comment letter to the Federal Deposit Insurance Corporation (FDIC) in support of their proposal to strengthen regulations under the Change in Bank Control Act (CBCA).

Letters to Regulators: Equitable and Just Green Lending Starts with Strong Consumer Protections

AFREF led a letter signed by 45 environmental justice, energy, consumer, housing, and other organizations urging federal agencies to (1) require consumer protection plans for green lending products across all federal programs, and (2) provide oversight and enforcement around existing consumer protection laws which apply to these products. The letter lays out: Common challenges with green lending

Letters to Regulators: Letter to PCAOB in Support of Auditing Standards re: Company’s Noncompliance with Laws and Regulations

AFREF joined Public Citizen and other organizations in a letter to the Public Company Accounting Oversight Board (PCAOB) urging the board to strengthen and finalize its proposals to update AS 2405, A Company’s Noncompliance with Laws and Regulations, and AS 2110, Identifying and Assessing Risks of Material Misstatement. “The climate crisis and the economy-wide decarbonization

Letters to Regulators: IOSCO Should Explicitly Acknowledge That Environmental and Social Integrity Are Critical Components of the Market Integrity of Carbon Credits

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter on The Board of the International Organization of Securities Commissions (IOSCO)’s Consultation Report outlining a proposed set of Good Practices to promote the integrity and orderly functioning of Voluntary Carbon Markets (VCMs).  IOSCO has appropriately developed a proposed set of 21 Good Practices in

Letters to Regulators: CFTC Should Finalize Guidance and Continue Close Monitoring of Risks of Voluntary Carbon Credit Derivatives Contracts

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its proposed guidance for designated contract markets (“DCMs”) on commodity characteristics that should be considered in terms and conditions for the listing of voluntary carbon credit (“VCC”) derivative contracts. The letter recommends that first, the CFTC

Letters to Regulators: NCUA Budget for 2024-2025 Should Account for Climate-Related Financial Risk to Credit Unions and Consumer Protection Needs

Americans for Financial Reform Education Fund led and submitted a comment letter, to the NCUA on the agency’s draft 2024-2025 budget. The letter was endorsed by Green America, the National Coalition for Asian Pacific American Community Development, the National Fair Housing Alliance, New York Communities for Change, Public Citizen, and The Greenlining Institute. The letter

Letters to Regulators: CFPB Should Finalize Residential PACE Rule and Develop Consumer Protections for Emerging Green Lending Products

Americans for Financial Reform Education Fund submitted a comment letter, endorsed by 20 partner organizations, to the Consumer Financial Protection Bureau (CFPB)’s proposed rule on residential Property Assessed Clean Energy (PACE) financing.  The letter urges the CFPB to finalize the residential PACE rule swiftly to protect consumers. In addition, it recommends that the CFPB monitor

Letters to Regulators: Comment Letter in Support of the SEC’s Proposal to Modernize Beneficial Ownership Reporting

AFREF, the AFL-CIO, Communications Workers of America, the Interfaith Center on Corporate Responsibility, and Public Citizen submitted a comment letter in support of the SEC’s proposal to modernize beneficial ownership reporting in response to a new memorandum by the Division of Economic and Risk Analysis.

Letters to Regulators: Comment Letter to FHFA on Language Access, Fair Lending Oversight, and EHF

The Language Access Task Force of Americans for Financial Reform (AFR) submits the following comments in strong support of the Federal Housing Finance Agency (FHFA)’s Notice of Proposed Rulemaking on Fair Lending Oversight and Equitable Housing Finance.

Letters to Regulators: NCUA Should Bolster Staff Capacity, Training, Tools, Research & Analysis, and Guidance on Climate-related Financial Risk

Americans for Financial Reform Education Fund submitted a comment letter endorsed by The Greenlining Institute and Public Citizen, in response to the National Credit Union Administration (NCUA)’s request for information on climate-related financial risk. The letter urges the NCUA to proceed with critical next steps to help credit unions monitor and manage their climate-related financial

Letters to Regulators: PCAOB Should Update “General Responsibilities” of Auditors, Address Climate Accounting Estimates and Assumptions

AFREF joined Public Citizen in responding to the Public Company Accounting Oversight Board’s request for comment on General Responsibilities of the Auditor in Conducting an Audit (AS 1000). We commended the PCAOB for proposing to extend an auditor’s evaluation of fairness in AS 2810 beyond “mere technical compliance with the applicable financial reporting framework,” to

Letters to Regulators: Letter to Treasury, OCC, FRB and FDIC on the Need to Fight Bank Consolidation

The President has made it clear: it’s time to fight consolidation, not facilitate it. In reviewing lessons learned from this most recent banking crisis to better prevent the next one, the regulators must be full-throated and clear in their affirmation that robust regulation and competition, not consolidation, will lead to a healthier, safer, and more vibrant financial system. Banks must exist to serve the needs of the American people, not the other way around – and it is regulators’ critical task to ensure so. 

Letters to Regulators: Comment on OIRA Cost Benefit Analysis Guidance

AFREF submitted comments to the Office of Information and Regulatory Affairs on its proposal to modernize the regulatory process to better account for racial and economic inequality, climate change, and other factors within economic analysis; and improve transparency and empower and benefit members of marginalized communities through the regulatory process.

Letters to Regulators: EPA Should Continue to Develop Greenhouse Gas Reduction Fund Guidance that Delivers Tangible Benefits to Low-Income and Disadvantaged Communities Across the Country

May 12, 2023 Americans for Financial Reform Education Fund (AFREF) submitted an environmental justice advocates comment letter signed by Public Citizen and WE ACT for Environmental Justice to the Environmental Protection Agency (EPA) on its Implementation Framework for the Greenhouse Gas Reduction Fund.  The Implementation Framework charts a path towards an environmental and climate justice-aligned

Letters to Regulators: Letter to the SEC on Finalizing a Strong Set of Rules to Better Protect Investors in Private Funds

Americans for Financial Reform Education Fund and 12 other signers submitted a letter to the Securities and Exchange Commission reiterating the need for the SEC to finalize a strong set of rules to better protect investors in private funds, which include hedge funds and private equity.

Letters to Regulators: Letter to CMS on Proposed Rule on Ownership of Nursing Facilities

AFREF submitted a comment to the Centers for Medicare and Medicaid Services (CMS) on their proposed rule to require the disclosure of important information regarding the ownership and control of nursing facilities, including when an owning or managing entity is a private equity (PE) company or a Real Estate Investment Trust (REIT).

Private equity and healthcare are incompatible and AFREF states in the letter that the current lack of transparency in ownership of facilities exacerbates the problem and shields owners and investors from accountability for the performance of the businesses they own and welcomes the disclosure rule.

Letters to Regulators: Letter Supporting CFPB Safe Harbor for Credit Card Late Fees

AFREF joined a comment letter that strongly supports the CFPB’s proposed safe harbor of $8 for credit card late fees. The CFPB provided ample evidence that this amount is fair, reasonable, and proportional to the costs incurred by issuers for late payments.