Category Archives: Education Fund

a pile of credit cards

Letters to Regulators: Letter to NCUA Opposing Proposed Change to Overdraft Policy

AFR Ed Fund joined our colleagues to send a letter opposing the National Credit Union Administration’s proposal to permit federal credit unions to leave negative account balances open for longer than the current limit of 45 days without any limits on overdrafts, overdraft fees, or NSF fees that can be assessed during this period. This proposal fails to consider the substantial risks it poses on credit union members who are facing economic challenges during the pandemic by exposing them to additional fees that only compound their financial distress.

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a series of houses

New Release: AFREF Statement: Consumer, Civil Rights, Housing and Small Business Groups Urge the Federal Reserve Board to Strengthen Community Reinvestment Act Framework with Focus on Increasing Equity in Bank Investments and Access to Sustainable Credit for Communities of Color and Low and Moderate Income Families

Americans for Financial Reform Education Fund (AFREF) and 20 consumer, civil rights, small business, and other public interest partners submitted a comment letter to the Federal Reserve Board of Governors (FRB) on its Advance Notice of Proposed Rulemaking to modernize the Community Reinvestment Act (CRA).

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Federal reserve board

Letters to Regulators: Letter in Response to the Federal Reserve Board’s ANPR on the Community Reinvestment Act

Americans for Financial Reform Education Fund organized a letter to the Federal Reserve Board (FRB) in response to their advanced notice of proposed rule making (ANPR) on the Community Reinvestment Act (CRA). The letter outlined a number of guiding principles and approaches to ensure that any changes to the CRA framework would be limited to measures that will increase equity in bank investments and access to sustainable, wealth-building credit in underserved communities as the statute intended.

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A pair of hands writing on paper with a pen

Letters to Regulators: Joint Letter Opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program

AFR Education Fund signed onto a letter opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program. The letter stated that the proposal cannot achieve its goal of providing a solution for veteran borrowers’ COVID hardships, and urged the VA to revise the proposal to align with existing programs at FHA, USDA, and the Government Sponsored Enterprises. Specifically, the letter stated that the VA should not require monthly payments, funds should not accrue interest, access to the program should be streamlined, and the program should not have a limited time window for relief.

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dollar bills and coins

Letters to Regulators: Predatory Lending Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

Americans for Financial Reform Education Fund signed onto a predatory lending letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it was inconsistent with the agency’s fundamental charges to ensure safety and soundness, consumer protection, fair lending, and the aims of the Community Reinvestment Act. The letter stated that the OCC did not have the authority to make such a proposal, and that it created an unmistakable and absolute conflict by pressuring banks to finance lenders whose models are driven by unaffordable lending.

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sunrise over a field of wind turbines

Letters to Regulators: Climate Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

Americans for Financial Reform Education Fund signed onto a comment letter, organized by Public Citizen, opposing the OCC’s proposed rule “Fair Access to Financial Services” due to climate concerns. The letter urged the OCC to withdraw the proposal on the basis that it required banks to serve every category of high-risk business, with the express goal of increasing bank lending to risky fossil fuel companies and other polluting sectors, and without regard for strategic or reputational risk. The letter stated that the OCC lacked the legal authority to enact this proposed rule, that banks are acting prudently to exit the fossil fuel industry because of growing climate risk to the sector, and that the OCC should instead scrutinize and curb banks’ involvement with high-emission activities.

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a house behind bushes

Letters to Regulators: Housing Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

Americans for Financial Reform Education Fund signed onto a housing letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it is a perversion of long-held anti-discrimination principles. The letter stated that the OCC appropriated civil rights language to protect market activities, drafted vague and unintelligible standards, undermined the ability of financial institutions to consider important facets of reputational risk in making investment and underwriting determinations, and provided a negligently inadequate 45-day comment period in the midst of the COVID crisis.

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A gavel on top of a pile of currency

Letters to Regulators: Letters to OCC about Oportun’s Application for a National Bank Charter

Americans for Financial Reform Education Fund signs onto two comment letters to the OCC about Oportun’s application for a national bank charter. The letters express several concerns about Oportun’s practices regarding debt collection, lending and Community Reinvestment Act compliance planning. They urge the OCC to condition Oportun’s charter upon substantial improvement of these practices.

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