AFREF sent a letter to the CFPB in response to their Request for Information regarding employer-driven debt.
Letter to Regulators: Comment in Response to ED Notice of Proposed Rulemaking on Prison Education Programs, 90/10 and Change of Ownership
AFREF joined a comment letter in response to the Education Department’s Notice of Proposed Rulemaking on prison education programs, 90/10 and change of ownership.
Letter to Regulators: Letter to Treasury on How to Increase Transparency in the U.S. Treasury Market”
AFREF sent a letter to the Treasury Department on how to increase transparency in the U.S. Treasury market.
AFREF sent a roadmap for action to the Federal Reserve.
AFREF joined the National Community Reinvestment Coalition, the National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending in sending a letter to the FDIC saying that Ford Motor Company should be denied deposit insurance for its proposed new Ford Credit industrial loan company (ILC) charter.
AFREF and CRL led a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank.
Letters to Regulators: Letter to the SEC in Response to Request for Comment on Certain Information Providers Acting as Investment Advisors
AFREF sent a letter to the Securities and Exchange Commission supporting its proposal to treat index providers as investment advisers given the many traits of index providers that resemble investment advice.
Such proposals are necessary as index funds have grown to become a multi-trillion dollar industry but one whose decisions to include or exclude issuers from the indices, and which many fund managers must closely follow, remain opaque and feature a number of conflicts-of-interest.
AFREF sent a letter to FHFA on their Duty to Serve plans.
Letters to the Administration: Letter Asking President Biden to Extend and Expand Access to PSLF and IDR Waiver
AFFEF joined a letter urging President Biden to extend, expand, and coordinate more closely the current Public Service Loan Forgiveness waiver and Income-Driven Repayment Adjustment in order to fulfill the promise of affordable and manageable loan repayment for borrowers.
Letters to Regulators: Letter to the SEC Commenting on Listing Standards for Recovery of Erroneously Awarded Compensation
AFREF submitted a comment letter in support of the SEC’s proposed rule on clawbacks of erroneously-awarded executive compensation. Once finalized, the rule will signify the long-overdue implementation of a Dodd-Frank provision that sought to improve incentives for honest and transparent corporate governance by creating a mechanism for the clawing back of compensation awarded based on inaccurate financial statements. AFREF submitted a comment in support of the proposed rule in 2015, and submitted this additional comment to answer questions raised by the Commission upon reopening the comment period