Letter to HUD opposing the set of deregulatory efforts now under way that are withdrawing crucial commonsense oversight from the housing and financial markets, enabling discrimination, and thereby increasing barriers to affordable housing
In August regulators issued a rule that dramatically weakened the Volcker Rule limits on direct proprietary trading by banks. Today, they have proposed new changes that would greatly weaken restrictions on banks taking risks through ownership of external funds, including venture capital funds and securitization vehicles like collateralized debt obligations.
Yesterday, the House passed the Comprehensive Credit Reporting Enhancement, Disclosure, Innovation, and Transparency Act of 2020 (Comprehensive CREDIT Act), H.R. 3621, in a 221-189 vote.
AFR Education Fund wrote a letter to banking regulators urging them to maintain risk controls for derivatives transactions at large banks Download the letter here. January 23, 2020 RE: Margin and Capital Requirements for Covered Swaps Entities (OCC Docket ID OCC–2019– 0023; Federal Reserve
AFR and 84 organizations sent a letter in support of the Comprehensive CREDIT Act of 2020, which would make the credit reporting system more accurate and fairer to consumers.
In revising the Volcker Rule’s proprietary trading ban last year, the regulators had already relaxed one component of the limits on investment in funds, clarifying the industry’s ability to do so on behalf of clients. Backing off some of the fund restrictions will “complete the process of neutering the rule,” Marcus Stanley, policy director at Americans for Financial Reform, said in a criticism of the regulators’ actions last year.
While the statement purports to clarify the standard for abusiveness under the law, in fact it inserts a great deal of vagueness, and signals that the CFPB is prepared to give companies a pass when they commit abusive acts. And the Bureau plans to let companies that have used abusive practices off the hook for civil penalties and disgorgement if they acted in good faith—a standard that will be in the eye of the beholder, that will encourage ignorance of the law, and that will require the CFPB to prove a negative.
AFR Ed Fund joined our partners in a letter to the USDA addressing proposed changes to strengthen and improve loss mitigation options for RHS borrowers.
Consumer advocates and academics criticized the policy, saying the agency was effectively tying its own hands. “It seems that the agency is trying to highly constrict the use of ‘abusive’ by using terms that do not fully capture the way lenders behave,” said Linda Jun, an attorney at the advocacy Americans for Financial Reform.
The amici submitting this brief are consumer organizations with an interest in the constitutional analysis that determines whether the structure of the Consumer Financial Protection Bureau (CFPB) is consistent with separation-of-powers principles … The amici submitting this brief are consumer organizations with an interest in the constitutional analysis that determines whether the structure of the Consumer Financial Protection Bureau (CFPB) is consistent with separation-of-powers principles …