AFREF joined our partners in sending a letter calling on the OCC to carefully scrutinize new partnerships between risky Income Share Agreement companies and banks under OCC supervision. Partnerships like the one between Mentorworks and Blue Ridge Bank have the potential to put borrowers at risk by opening the market to a product that is violating the law & harming borrowers.
AFREF and 17 organizations sent a letter in response to FHFA’s RFI on climate and natural risk management detailing our concerns about the disproportionate impact of climate change and natural disasters on borrowers and communities of color and low and moderate income neighborhoods. We provided recommendations for next steps on FHFA’s work on mitigating climate risk and urged FHFA to make sure climate risk mitigation efforts do not cause inadvertent harm to the communities who are already most vulnerable to the adverse effects of climate change and who face the most challenges in accessing and sustaining homeownership.
The AFR Education Fund sent a letter to the Securities and Exchange Commission responding to a request for comment on regulatory options for money market funds in light of the collapse and bailout of many money market funds during the March 2020 coronavirus financial shock. The letter called for strong new regulatory steps to fix incentives that create financial instability for these products. It also questioned whether additional regulation should be extended to other types of fixed-income investment funds beyond money market funds narrowly defined, as there is evidence that these types of fund arrangements can also contribute to financial instability.
AFREF joined our partners in sending a follow-up letter calling on the CFPB to rescind its April 1, 2020 guidance allowing consumer reporting agencies and furnishers to exceed the dispute investigation deadlines under the Fair Credit Reporting Act. In the six months since we sent our last letter, the situation has only gotten worse, with nearly 26,000 more complaints submitted by consumers about delayed or nonexistent responses to credit/consumer reporting disputes. We urged the Bureau to revoke the guidance as soon as possible to prevent further consumer harm.
AFREF joined a letter opposing the Office of Management and Budget’s proposal to redefine metropolitan statistical areas. The OMB’s proposal would result in a substantial loss for undeserved and under-invested communities by reducing the number of low and moderate income census tracts eligible for Community Reinvestment Act credit and decreasing the number of banks providing Home Mortgage Disclosure Act data, which may pose increased challenges to fair lending enforcement.
The American Federation of Teachers is advising its pension trustees with more than $3 trillion under management to review their private equity investments after a new report exposed the diminished returns and structural risks associated with the industry.
AFREF joined our partners to send a letter urging HUD to take further steps to protect FHA borrowers facing COVID-related hardships form foreclosure, including requiring servicers to communicate the availability of several loss mitigation options, providing guidelines for contacting borrowers before the end of a forbearance, and collect performance data on COVID-19 loss mitigation options and make this information available to the public.