AFREF joined the National Community Reinvestment Coalition, the National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending in sending a letter to the FDIC saying that Ford Motor Company should be denied deposit insurance for its proposed new Ford Credit industrial loan company (ILC) charter.
AFREF and CRL led a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank.
AFREF sent a letter to the Securities and Exchange Commission supporting its proposal to treat index providers as investment advisers given the many traits of index providers that resemble investment advice.
Such proposals are necessary as index funds have grown to become a multi-trillion dollar industry but one whose decisions to include or exclude issuers from the indices, and which many fund managers must closely follow, remain opaque and feature a number of conflicts-of-interest.
AFREF sent a letter to FHFA on their Duty to Serve plans.
AFFEF joined a letter urging President Biden to extend, expand, and coordinate more closely the current Public Service Loan Forgiveness waiver and Income-Driven Repayment Adjustment in order to fulfill the promise of affordable and manageable loan repayment for borrowers.
AFREF submitted a comment letter in support of the SEC’s proposed rule on clawbacks of erroneously-awarded executive compensation. Once finalized, the rule will signify the long-overdue implementation of a Dodd-Frank provision that sought to improve incentives for honest and transparent corporate governance by creating a mechanism for the clawing back of compensation awarded based on inaccurate financial statements. AFREF submitted a comment in support of the proposed rule in 2015, and submitted this additional comment to answer questions raised by the Commission upon reopening the comment period
AFREF submitted and joined coalition comment letters in response to the Securities and Exchange Commission (SEC)’s proposed rule on climate disclosure. The coalition letters focused on Environmental Justice, Community Impacts, and Indigenous rights.
AFREF sent a Follow Up Comment to the Securities and Exchange Commission expressing support for its proposals that would require private fund advisers to provide their investors with greater and more detailed information around the fees, expenses, returns, and bilateral investment relations (via side letters). We echo many of the comments the SEC has since received since its initial comment period and reflect how current market conditions make the Commission’s proposals especially a priority given the variation in the reporting and valuation of private market assets.
AFREF sent a letter to the Securities and Exchange Commission expressing its support for its many proposals that would amend the definition of a “blank check company” to include the current and any future iterations of Special Purpose Acquisition Companies (SPACs). Such proposals would impose greater liability on many involved in the creation and distribution of SPACs and provide investors with greater transparency into the forward looking projections that the issuers of SPACs have been misleadingly overly optimistic with.
AFREF and Public Citizen sent a letter to PCAOB in response to their request for comment on their Interim Analysis of Estimates and Specialists Audit Requirements.