Category Archives: Education Fund

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.  

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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. 

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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.

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lawyer signing a document Photo by Helloquence on Unsplash

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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