Category Archives: Education Fund

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Letters to Regulators: Letter in Response to the Department of Commerce’s RFI on the Implementation of the CHIPS Incentives Program

AFREF led thirteen partners in submitting a comment letter in response to a Department of Commerce request for information on the implementation of the CHIPS incentives program.  The letter describes how stock buybacks and outsized executive compensation packages undermine innovation and inclusive economic growth, and details the semiconductor industry’s track record of massive spending on stock buybacks and CEO compensation. It then recommends bright-line rules to restrict stock buybacks and executive compensation, as well as pro-worker policies that would promote innovation and inclusive economic growth.

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A pair of hands writing on paper with a pen

Letters to Regulators: Comment Letter on Fintech and Housing Finance

AFREF joined experts in the field in submitting comments calling on the FHFA Office of Financial Technology to ensure that new applications of fintech to housing finance do not violate consumer protections or fair housing violations. Specific recommendations are made to avoid algorithmic bias and e-signature fraud, along with a general principle of caution when approving new fintech practices.

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Letters to Regulators: Letter Telling Fannie and Freddie to Finance Affordable Housing, Not Displacement

AFREF and 34 allies sent a letter regarding the Safety and Soundness Act, which requires FHFA to establish annual housing goals for mortgages purchased by Fannie Mae and Freddie Mac (the Enterprises). This letter supports the proposal’s move towards a methodology that focuses on the percentage, not number, of affordable housing units financed by the Government Sponsored Enterprises (GSEs). However, the proposal fails to hold the GSEs to adequate lending standards and refine what counts as affordable housing units. 

This letter seeks policy reforms that will prevent GSEs from financing loans that contribute to displacement and substandard living conditions for low income tenants and tenants of color. It also objects to FHFA goals being set at levels that are below recent performance by the Enterprises.

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Letters to Regulators: Letter to the SEC and CFTC on Proposed Amendments to Form PF

AFREF sent a letter in support of proposals from both the Securities and Exchange Commission and Commodity Futures Trading Commission that would provide the agencies and by extension the Financial Stability Oversight Council with additional information from the $18 trillion private fund industry related to: more specific details about their holdings in digital assets, more granular data around derivatives and swaps that reference corporate debt and information about the base currencies their holdings are denominated in. Such information will help regulators ensure that they have a clearer picture into the holdings and risks posed by the $18 trillion private fund industry in order to be able to react proactively to any risks that may threaten the financial system.

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