AFREF led a letter calling on the SEC’s Division of Corporation Finance to rescind the 2010 Ford Motor Credit no-action letter that exempts Credit Rating Agencies from legal liability.
AFREF joined a letter in response to the Department of Education’s request for comment on accrediting agencies up for review in February 2023.
AFREF joined a letter to FHFA calling on the agency to rededicate itself to improving language access in mortgage origination and servicing.
AFREF submitted a comment letter to the Securities and Exchange Commission supporting several changes to Rule 10c-1 of the Securities Exchange Act of 1934 that would provide investors and regulators with significantly more information into the currently opaque $1.5 trillion securities lending market.
AFREF submitted a comment on the CFPB’s proposal to collect small business lending data to enforce fair lending laws.
AFREF joined a letter to the CFPB in response to their inquiry into Big Tech payment platforms. The letter urges the CFPB to require person-to-person payment providers to protect consumers from fraud and errors, and to work with the Federal Reserve Board to ensure protections are in place before the Fed launches its new FedNow person-to-person service.
AFREF joined a letter urging CFPB oversight of new products like buy now, pay later (BNPL) loans, income share agreements, cash advances, “fintech” overdraft or overdraft avoidance products, and earned wage access products or look-alike products that are evading consumer protection laws and creating debt traps for consumers. The letter states that the CFPB should supervise providers and ensure that each of these products are complying with applicable consumer protection laws.
AFREF, American Economic Liberties Project and Revolving Door Project sent a letter to the CFPB in response to their inquiry into Big Tech payment platforms. The letter expresses concern about Big Tech exploitation of digital payments technology, and expresses support for their recently opened inquiry into Big Tech’s power in this vital and growing market.
AFREF joined more than 100 groups in a letter calling on the CFTC to shut down the dangerous water futures market.
AFREF led a letter urging the Financial Stability Oversight Council (FSOC) as the coordinating body for several regulatory agencies to imminently take action against the various misdeeds that may be conducted by the issuers of stablecoins. The letter explains that such urgency cannot be overstated given how quickly the market continues to grow, posing greater threats to the broader financial system.