Category Archives: Education Fund

Letter to Regulators: The Fed must recognize its own regulatory failures and take action in the wake of Archegos

Americans for Financial Reform Education Fund wrote the Fed to express concerns over the blow-up of the Archegos family fund. This incident reveals both the dangers of excessive leverage at private funds, and the failure of banking regulators, including the Federal Reserve, to properly regulate bank interactions with such funds. To address these issues, the Federal Reserve must investigate its own regulatory failures in this case and publicly disclose the lessons learned from this investigation, and must also work with the Financial Stability Oversight Council to address the risks of excessive leverage at private funds.

A pair of hands writing on paper with a pen

Letters to Regulators: Letter to the OCC to Scrutinize New Partnerships Between Risky Share Agreement Companies and Banks

AFREF joined our partners in sending a letter calling on the OCC to carefully scrutinize new partnerships between risky Income Share Agreement companies and banks under OCC supervision. Partnerships like the one between Mentorworks and Blue Ridge Bank have the potential to put borrowers at risk by opening the market to a product that is violating the law & harming borrowers.

by
a green forest with a tornado looming

Letters to Regulators: Letter in Response to FHFA RFI Expressing Concerns About Climate and Natural Risk Management

AFREF and 17 organizations sent a letter in response to FHFA’s RFI on climate and natural risk management detailing our concerns about the disproportionate impact of climate change and natural disasters on borrowers and communities of color and low and moderate income neighborhoods. We provided recommendations for next steps on FHFA’s work on mitigating climate risk and urged FHFA to make sure climate risk mitigation efforts do not cause inadvertent harm to the communities who are already most vulnerable to the adverse effects of climate change and who face the most challenges in accessing and sustaining homeownership.

by

Letters to Regulators: AFR Education Fund Calls on SEC for Stronger Regulation of Funds in Wake of March 2020 Bailout

The AFR Education Fund sent a letter to the Securities and Exchange Commission responding to a request for comment on regulatory options for money market funds in light of the collapse and bailout of many money market funds during the March 2020 coronavirus financial shock. The letter called for strong new regulatory steps to fix incentives that create financial instability for these products. It also questioned whether additional regulation should be extended to other types of fixed-income investment funds beyond money market funds narrowly defined, as there is evidence that these types of fund arrangements can also contribute to financial instability.

by
sign for the CFPB outside a building

Letters to Regulators: Letter to the CFPB Re: Renewed Request to Rescind Language in April 1, 2020 CFPB Guidance Allowing CRAs and Furnishers to Exceed FCRA Deadlines for Disputes

AFREF joined our partners in sending a follow-up letter calling on the CFPB to rescind its April 1, 2020 guidance allowing consumer reporting agencies and furnishers to exceed the dispute investigation deadlines under the Fair Credit Reporting Act. In the six months since we sent our last letter, the situation has only gotten worse, with nearly 26,000 more complaints submitted by consumers about delayed or nonexistent responses to credit/consumer reporting disputes. We urged the Bureau to revoke the guidance as soon as possible to prevent further consumer harm. 

by
the front side of an apartment building

Letters to Regulators: Letter to the OMB Opposing Proposed Redefinition of Metropolitan Statistical Areas

AFREF joined a letter opposing the Office of Management and Budget’s proposal to redefine metropolitan statistical areas. The OMB’s proposal would result in a substantial loss for undeserved and under-invested communities by reducing the number of low and moderate income census tracts eligible for Community Reinvestment Act credit and decreasing the number of banks providing Home Mortgage Disclosure Act data, which may pose increased challenges to fair lending enforcement.

by