All posts by team

News Release: Gensler Will Bring Strong Track Record to SEC in Need of Reform

Gary Gensler has a strong track record from his time at the Commodities Futures Trading Commission of being willing to take on powerful industries. Under his leadership, this small and underfunded agency led the way to the first comprehensive regulation of U.S. over-the-counter derivatives markets, despite heavy opposition from industry lobbyists. Gensler will need to bring the same spirit and drive to the even greater task of bringing needed reform to the Securities and Exchange Commission.

A pair of hands writing on paper with a pen

Letters to Regulators: Joint Letter Opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program

AFR Education Fund signed onto a letter opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program. The letter stated that the proposal cannot achieve its goal of providing a solution for veteran borrowers’ COVID hardships, and urged the VA to revise the proposal to align with existing programs at FHA, USDA, and the Government Sponsored Enterprises. Specifically, the letter stated that the VA should not require monthly payments, funds should not accrue interest, access to the program should be streamlined, and the program should not have a limited time window for relief.

dollar bills and coins

Letters to Regulators: Predatory Lending Joint Letter 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.

sunrise over a field of wind turbines

Letters to Regulators: Climate Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

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.

a house behind bushes

Letters to Regulators: Housing Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

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.

Blog Post: How a Politically Connected Private Equity Firm Scored a Special Bailout for its Heavily Indebted Trucking Company

Private equity giant Apollo Global in 2019 lent large sums of money to trucking company YRC Worldwide. After Apollo’s executives reached out to the White House on getting bailouts in the spring, YRC managed, under mysterious circumstances, to be the greatest beneficiary of a special loan program for companies critical to national security.