Category Archives: Education Fund

Letters to the Regulators: Letter to the SEC Supporting the Prohibition of Conflicts of Interests in Securitization

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.

by
lawyer signing a document Photo by Helloquence on Unsplash

Letters to Regulators: Comment on OIRA Cost Benefit Analysis Guidance

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.

by

Letters to Regulators: Letter to CMS on Proposed Rule on Ownership of Nursing Facilities

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.

by

Letters to Regulators: Letter to the FTC to Ban Non-Compete Clauses

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.

by

Letters to Regulators: EPA RFI on Environmental and Climate Justice Block Grant 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.

by