View or download a PDF of the letter here. The Americans for Financial Reform Education Fund today submitted a comment opposing a proposal by the New York Stock Exchange and the Securities and Exchange Commission that would end annual shareholder meetings for closed-end funds. Closed-end
Today, nearly 100 consumer advocacy, civil rights and community organizations and academics submitted a supportive comment on the Consumer Financial Protection Bureau’s (CFPB) Buy Now, Pay Later (BNPL) Interpretive Rule. These groups strongly support the CFPB’s proposal, which simply clarifies that accounts used to access BNPL credit are credit cards that must comply with credit card rules governing disputes, errors, periodic statements and disclosures. Those protections will enhance the safety of BNPL credit and make it easier for consumers to manage their finances.
“Despite the industry’s rhetoric around this, the shift in position from policymakers in Congress and other parts of Washington is not based on the substance of the industry’s policy arguments,” said Mark Hays, senior policy analyst at Americans for Financial Reform, a nonprofit advocating for financial reform, and Demand Progress, a nonprofit progressive advocacy group. “The industry likes to say that this is true proof that there’s a so-called crypto voter, that crypto is a major election outcome or a major election issue. But I just feel like it’s sort of the same old pay-to-play Washington politics,” Hays added.
The Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission and the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) supporting the proposal to require the $125 trillion in Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (mainly Venture Capital) to implement Customer Identification Programs to better understand who the beneficial owners of their funds are.
More opposition came from Patrick Woodall, managing director for policy at Americans for Financial Reform, a nonprofit coalition consisting of more than 200 consumer, civil rights, labor, business and investor organizations. “It would be irresponsible for the regulators to approve this merger after Capital One has repeatedly broken its promises made to secure previous mergers,” Woodall said. “It shut down two-thirds of its branches after promising to maintain its geographic footprint. It stopped making home purchase and home improvement mortgages after promising to maintain service levels.”
Today, Americans for Financial Reform and many allies will take our case directly to federal banking regulators and demand that they block the proposed Capital One-Discover merger. Federal regulators have rubber stamped thousands of bank mergers over the past few decades, consolidating the industry to create risky megabanks, reducing choices and raising prices for depositors and small businesses. The wave of mergers beginning in the mid-1990s contributed to the contagious fragility of the banking system during the 2008 financial crisis. Here are the top 10 reasons to block this merger:
Since Capital One announced plans to take over Discover, reasons to oppose the creation of this new megabank have only grown. As federal regulators convene a hearing today on this risky merger, they must face the key arguments, which public interest groups will make, against it: the merger would reduce competition in the already concentrated credit card industry, it poses risks to the stability of the financial system, it would raise network fees for merchants, and it does not deliver for communities.
The proposed acquisition of Discover by Capital One would create the sixth-largest bank in the United States, with $624 billion in domestic assets. This transaction fails to meet the public interest conditions under the Bank Merger Act that directs banking regulators to reject mergers, like the Capital One-Discover transaction, that fail to further the convenience and needs of communities.
The proposed Capital One takeover of Discover would create a mammoth bank that would undermine competition, raise prices, and harm consumers. The merger would create the biggest credit card lender — holding nearly one-third of credit card loans to consumers with non-prime credit scores — and put Capital One in a position to use its market power to raise prices on virtually captive consumers.
Christine Zinner, policy counsel at Americans for Financial Reform, said the paycheck advance products “are nothing more than workplace payday loans, with consumers (being) more easily preyed upon since the money is only a tap away on a cell phone.” “People can easily become trapped in a cycle of debt by re-borrowing, requesting advances 12 to 120 times each year, just to pay basic household expenses and make ends meet,” she said.