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.”
AFR released the policy brief linked below concerning the role of private equity in the Toys R’ Us bankruptcy and the importance of taking action to limit private equity predation on the businesses they own. The Toys R’ Us Bankruptcy And Private Equity Predation.
“What Mulvaney is really interested in is not serious research, but information that advances the interests of the Wall Street banks and predatory lenders he serves.”
“America is facing an ongoing student debt crisis, with outstanding student debt surpassing $1.5 trillion and over 8 million borrowers in default on their student loans. Closing the Office for Students is like shuttering the fire department in the middle of a three-alarm fire,” said Alexis Goldstein, senior policy analyst at Americans for Financial Reform.