Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission (SEC) supporting its proposal to prohibit conflicts of interest in securitizations. Such conflicts were at the heart of the Great Financial Crisis of 2008 leading to trillions of dollars in losses across the financial system and irreparable harm to millions of homeowners. Now, with the growth in securitizations such as those backed by commercial real estate and other assets, the SEC’s proposals can ensure that similar practices do not happen again at the harm of investors and others.
AFREF submitted comments to the Office of Information and Regulatory Affairs on its proposal to modernize the regulatory process to better account for racial and economic inequality, climate change, and other factors within economic analysis; and improve transparency and empower and benefit members of marginalized communities through the regulatory process.
Americans for Financial Reform Education Fund and 12 other signers submitted a letter to the Securities and Exchange Commission reiterating the need for the SEC to finalize a strong set of rules to better protect investors in private funds, which include hedge funds and private equity.
AFREF submitted a comment to the Centers for Medicare and Medicaid Services (CMS) on their proposed rule to require the disclosure of important information regarding the ownership and control of nursing facilities, including when an owning or managing entity is a private equity (PE) company or a Real Estate Investment Trust (REIT).
Private equity and healthcare are incompatible and AFREF states in the letter that the current lack of transparency in ownership of facilities exacerbates the problem and shields owners and investors from accountability for the performance of the businesses they own and welcomes the disclosure rule.
AFREF joined a comment letter that strongly supports the CFPB’s proposed safe harbor of $8 for credit card late fees. The CFPB provided ample evidence that this amount is fair, reasonable, and proportional to the costs incurred by issuers for late payments.
AFREF joined a letter led by the Open Markets Institute and supported by 50 labor and public interest groups urging the Federal Trade Commission (FTC) to ban non-compete clauses as well as functionally equivalent restraints such as training repayment agreement provisions (or TRAPs), for all workers.
AFREF joined partner organizations to comment on the FHA’s 203(k) Rehabilitation Mortgage Insurance Program, a program that provides critical financing for low- and moderate-income people seeking to purchase a home in need of repairs. The comment letter details a number of changes that would increase participation in the program.
AFREF submitted a comment letter in response to the Environmental Protection Agency’s request for information for the Environmental and Climate Justice Block Grant Program (ECJ Program), which provides funding for financial and technical assistance to carry out environmental and climate justice activities to benefit disadvantaged communities. The letter highlights the need for the ECJ Program to minimize barriers for the most climate-vulnerable applicants, prioritize the needs and perspectives of all underrepresented or historically marginalized community members, and prioritize projects that combat the harmful effects of bluelining by financial service providers.