Category Archives: Education Fund

Letters to Regulators: Letter to OSTP Raising Concerns about Limits of Blockchain Technology

AFREF and Demand Progress Education Fund submitted comments to the Office of Science and Technology Policy (OSTP) in response to the agency’s request for information regarding the risks, limitations and purported benefits of blockchain technology (including regarding central bank digital currencies), to help inform the government’s research and development agenda on blockchain. The submission raised concerns about the technological limits and risks of blockchain as used for both financial and non-financial applications, as well as a variety of risks, and urged the OSTP to take a more balanced and sober look at blockchain in view of these limitations.

by

Letters to Regulators: Letter From 29 Signers to the SEC on Passing Strong Final Rules on Private Fund Advisers to Protect Investors and the Financial System

AFREF led a letter with 29 signers to the Securities and Exchange Commission reiterating the important need to pass a strong set of final rules related to requiring private fund advisers to disclose a complete breakdown of fees/expenses, assumptions used to calculate returns, and the existence of side letters to investors.

The letter is also urging the SEC to finalize a strong set of rules related to requiring private fund advisers over a certain size to report more detailed information about their holdings confidentially to the SEC so that the SEC and other financial regulatory agencies have much greater insight into the risks in the $21 trillion private fund space where there is currently little visibility in order to better safeguard the financial system.

by

Letters to Regulators: Letter to ED on IDR Proposed Rulemaking

AFREF joined a letter to the Dept. of Education applauding the Department for the significant positive impact its proposed changes to the IDR rules could have on student loan borrowers.  The proposed rule has the ability to substantially reduce monthly and lifetime payments for millions of borrowers, raise the threshold for protected non-discretionary income, lower the share of discretionary income borrowers have to pay, waive unpaid interest, and decrease time to cancellation.

by
A book titled "Consumer Protection" on a desk with a gavel resting on top

Letters to Regulators: Letter to the FTC on Junk Fees

AFREF and partners led a letter to the FTC urging it to use its rulemaking authority to protect American consumers from junk fees and put money back into our pockets. Millions of consumers have expressed outrage at the imposition of service fees for live event tickets, “amenity” or “resort” fees charged by hotels, endless surprise rental car fees, hidden internet and cell phone charges, junk fees in the financial sector, and more. The federal government has taken a holistic approach to this problem, including the White House Competition Council, the Consumer Financial Protection Bureau (CFPB), the Department of Transportation (DOT) and now the FTC. 

by
SEC Building

Letters to Regulators: Letter to the SEC on Standards for Covered Clearing Agencies for U.S. Treasury Securities and Application of the Broker-Dealer Customer Protection Rule With Respect to U.S. Treasury Securities Fund Advisers

AFREF submitted a comment to the Securities and Exchange Commission (SEC) on December 27th supporting its proposals that would centrally clear the $27 trillion U.S. Treasury market, one of the largest and most systemically important markets in the world. 

Shockingly, despite the Treasury market’s importance, no one regulator has complete visibility into this market and the SEC’s proposals move closer to implementing the Inter-Agency Working Group on Treasury Market Surveillance’s (IAWG) recommendations to give regulators such as the SEC and the Financial Stability Oversight Council (FSOC) greater visibility and oversight.  

by
a green forest with a tornado looming

Letters to Regulators: Letter in Support of FIO’s Proposed Climate-Related Financial Risk Data Collection

AFREF led comments to the Federal Insurance Office in support of their proposed “Climate-Related Financial Risk Data Collection” from insurers. AFREF supports this data collection because the increasingly prevalent and severe weather hazards caused by climate change pose a massive threat to the housing stability, affordability, and safety of Americans nationwide. Purchasing insurance policies is one of the few actions individuals can take to protect their property from the effects of climate-driven natural disasters. Therefore, the cost and availability of insurance is deeply related to a household’s monthly housing costs and their ability to recover from damages following severe weather. 

by
a house behind bushes

Letters to Regulators: Comment in Response to HUD RFI on Small Mortgage Lending

AFREF joined the National Fair Housing Alliance and local, state, and national organizations to submit comments in response to HUD’s “Request for Information Regarding Small Mortgage Lending.” Our comments focus on the importance of residential small-dollar lending (SDL), which is essential to building wealth and family opportunity for communities of color and low- and moderate-income families throughout the nation. For too long, homes in lower-priced markets have been starved of quality, sustainable, mortgage credit, both subject to and contributing to a history of residential segregation, neighborhood disinvestment, and lost wealth-building opportunity. This comment letter makes a number of suggestions to the FHA regarding how it can better promote small mortgage loans.

by