Category Archives: Education Fund

Federal reserve board

Letters to Regulators: Letter to the Federal Reserve on Access to Fed Master Accounts and Financial Services

AFREF submitted a comment to the Federal Reserve on its “Proposed Guidelines for Evaluating Account and Service Requests” urging the Federal Reserve to limit access to its payments systems to well-regulated and well-supervised depository institutions to safeguard rules that protect consumers, ensure the stability of the payments system, and require community reinvestment.

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Letters to Regulators: Letter to OMB in Response to Racial Equity RFI

AFREF joined a letter to the Office of Management and Budget in response to their RFI asking for input on how to identify effective methods for assessing whether agency policies, programs, services, processes, and operations equitably serve all eligible individuals and communities, particularly those that are currently and historically underserved.

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Letters to Regulators: Letter Urging Financial Regulators to Consider Fair Lending Risks in Use of Artificial Intelligence

AFREF and 22 organizations submitted comments in response to the regulators’ Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning, urging the financial regulators to consider fair lending risks of using artificial intelligence and machine learning and enact safeguards to prevent disproportionate adverse impacts from the use of AI/ML models.

Letters to Regulators: Letter Asking for Restored Supervisory and Enforcement Tools in Mortgage Servicing Rules

AFREF, NCLC, NFHA and NHLP sent a letter to the CFPB, FRB, FDIC, OCC, NCUA and CSBS asking the agencies to update the April 3, 2020 Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the COVID-19 Emergency and the CARES Act to restore key supervisory and enforcement tools to incentivize servicers to properly handle applications for loss mitigation assistance and require servicers to send loss mitigation notices to borrowers, which are especially critical as forbearances come to an end in the coming months.