Category Archives: Education Fund

Letters to the Regulators: AFREF Comment to SEC/FinCEN on Customer Identification Programs for Private Funds and Venture Capital

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.

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Fact Sheet: Proposed Capital One-Discover Merger Fails to Meet Bank Merger Act Requirements

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.

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Fact Sheet: Antitrust Implications of the Proposed Capital One-Discover Merger

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.

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Letters to the Regulators: Letter to the Federal Housing Finance Agency in Support of the Title Acceptance Pilot Program

Americans for Financial Reform Education Funded joined with the National Consumer Law Center, the Consumer Federation of America, and other advocacy groups to express our support for recent announcements from Fannie Mae and Freddie Mac, reflecting their intention to explore carefully-crafted pilot programs aimed at reducing closing costs for homeowners–specifically, a “title acceptance” pilot program.

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Letters to the Regulators: Letter to the Public Company Accounting Oversight Board in Support of a Public Reporting Requirement

AFREF and 11 organizations submitted a comment letter to the Public Company Accounting Oversight Board (PCAOB) in support of a proposal to require public accounting firms to publicly report specified firm- and engagement-level metrics. If finalized, these metrics would provide investors, audit committees, and other stakeholders critical information to compare audit firms, make better-informed decisions, and enhance auditor accountability.

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Letters to the Regulators: AFR Submits Filing Opposing Capital One-Discover Merger for Failing to Meet Bank Merger Act Requirements

AFREF submitted a second brief with the Office of the Comptroller of the Currency and Federal Reserve calling on the banking regulators to reject the proposed Capital One-Discover merger. The proposed Capital One-Discover merger would have significant anti-competitive impacts that would harm consumers and communities. The merger also fails to meet the requirements and conditions of the Bank Merger Act and Bank Holding Company Act. It fails to meet the convenience and needs of communities by raising consumer credit card costs, having a record of misleading marketing and aggressive debt collection, and closing two-thirds of its branches over the past 15 years.

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