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Letters to Regulators: Comment Letter on Fintech and Housing Finance

AFREF joined experts in the field in submitting comments calling on the FHFA Office of Financial Technology to ensure that new applications of fintech to housing finance do not violate consumer protections or fair housing violations. Specific recommendations are made to avoid algorithmic bias and e-signature fraud, along with a general principle of caution when approving new fintech practices.

Media Advisory: Experts discuss judicial attempt to destroy CFPB funding  

Remarks and Q&A with prominent legal experts on the extreme attempt by the Fifth Circuit Court of Appeals to overturn CFPB’s payday lending rule and destroy the funding mechanism Congress created for the agency, a step that threatens to unleash chaos in consumer finance markets and inhibit the agency’s work in protecting consumers.

News Release: 5th Circuit Court of Appeal’s Decision on CFPB Funding is an Outrageous Undermining of Consumers’ Rights

On Wednesday, October 19, 2022, a three-judge panel in the 5th U.S. Circuit Court of Appeals agreed with the payday lenders trade association in ruling that the CFPB’s funding structure is unconstitutional because it does not go through Congressional appropriations. This line of attack toward the CFPB – via its funding – has nothing to do with actually caring about the constitution and everything to do with the big banks and predatory lenders trying to escape the oversight and enforcement actions of an agency focusing on protecting and defending consumers.

News Release: Federal Insurance Office Requests Critical Climate Data from Insurers

The Federal Insurance Office (FIO) proposed new reporting requirements for insurers to collect geographical data on how climate change is affecting the availability and affordability of homeowners, multi-peril commercial, and fire insurance, with a lookback period of five years to assess trends. This is a critical–and long-awaited–first step to quantify the growing homeowners’ insurance gap in the midst of worsening climate conditions. 

Letters to Regulators: Letter Telling Fannie and Freddie to Finance Affordable Housing, Not Displacement

AFREF and 34 allies sent a letter regarding the Safety and Soundness Act, which requires FHFA to establish annual housing goals for mortgages purchased by Fannie Mae and Freddie Mac (the Enterprises). This letter supports the proposal’s move towards a methodology that focuses on the percentage, not number, of affordable housing units financed by the Government Sponsored Enterprises (GSEs). However, the proposal fails to hold the GSEs to adequate lending standards and refine what counts as affordable housing units. 

This letter seeks policy reforms that will prevent GSEs from financing loans that contribute to displacement and substandard living conditions for low income tenants and tenants of color. It also objects to FHFA goals being set at levels that are below recent performance by the Enterprises.