The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC proposal addresses a wide range of issues surrounding this exemption.
“The proposed Borrower Defense rule sacrifices students’ rights in order to line the pockets of executives at for-profit colleges, an industry that has shown time and again that it will use taxpayer dollars to deceive and defraud its own students.” said Alexis Goldstein, AFR’s Senior Policy Analyst. “With this rule and its extreme and absurd barriers to relief, Devos effectively tells students that if a school scams them, they’re on their own.”
On July 17, 2018, AFR Policy Director Marcus Stanley offered testimony at a hearing entitled “Examining Capital Regimes for Financial Institutions,” before the Financial Institutions and Consumer Credit Subcommittee of the House Financial Services Committee.
Americans for Financial Reform sent a letter to the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation commenting on a proposal to phase-in the regulatory capital effects of implementing the new
Americans for Financial Reform sent a letter to the Federal Reserve Board of Governors and the Office of the Comptroller of the Currency to comment on a proposal that would reduce the minimum leverage ratio requirements for the largest U.S. banks. Click here to access
AFR commented on a Federal Reserve proposal that would integrate the capital requirements in its different capital regimes to institute new stress buffer requirements.
AFR was among 25 organizations that signed-on to comments by the National Consumer Law Center on evaluating undue hardship claims in student loan bankruptcy. You can view or download the PDF here.
AFR commented on the roll back of transparency disclosures to investors in the SEC proposed rule “Investment Company Liquidity Disclosures.”
For its Head of Consumer Protection, the FTC chose a lawyer, Andrew Smith, who worked for both payday lenders and Equifax. The FTC needs a someone with a record of consumer protection, not yet another industry lawyer
“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”