AFREF joined a letter led by the Open Markets Institute and supported by 50 labor and public interest groups urging the Federal Trade Commission (FTC) to ban non-compete clauses as well as functionally equivalent restraints such as training repayment agreement provisions (or TRAPs), for all workers.
AFREF joined partner organizations to comment on the FHA’s 203(k) Rehabilitation Mortgage Insurance Program, a program that provides critical financing for low- and moderate-income people seeking to purchase a home in need of repairs. The comment letter details a number of changes that would increase participation in the program.
AFREF submitted a comment letter in response to the Environmental Protection Agency’s request for information for the Environmental and Climate Justice Block Grant Program (ECJ Program), which provides funding for financial and technical assistance to carry out environmental and climate justice activities to benefit disadvantaged communities. The letter highlights the need for the ECJ Program to minimize barriers for the most climate-vulnerable applicants, prioritize the needs and perspectives of all underrepresented or historically marginalized community members, and prioritize projects that combat the harmful effects of bluelining by financial service providers.
AFREF led 14 organizations in the housing, consumer protection, climate, civil rights, and community investment spaces, in a letter to the Federal Housing Finance Agency regarding the Federal Home Loan Bank system, arguing for expanded contributions to affordable housing to justify the public investment in the system, and for the system to undertake a number of initiatives to support members in reducing their climate risk and climate vulnerability.
AFREF joined a comment to the CFPB supporting the Bureau’s proposal to require nonbank covered persons that are subject to certain agency and court orders to register those orders with the CFPB. The registry will help the CFPB, law enforcement community, and the public limit the harms from repeat offenders.
AFREF, the Institute for Policy Studies, Global Economy Project, and Public Citizen led a letter with 22 additional signatories to the agencies tasked with implementing section 956 of Dodd-Frank. That section tasked six agencies with promulgating regulations to prevent incentive-based executive compensation that encourages “inappropriate risk” by May 2011. Almost 12 years later, we don’t have a final rule. The letter was sent to regulators ahead of congressional hearings that will examine recent bank failures.
AFREF and the Institute for Policy Studies, Global Economy Project led a comment letter to the Office of Management and Budget (OMB) about its uniform guidance, which sets the boundaries around the types of strings states and localities are allowed to attach when they disburse federal funds. This comment letter argues state and local governments should be allowed to give preferential treatment to bidders that commit to make productive investments in their companies and refrain from stock buybacks and excessive executive compensation.
AFREF and Demand Progress Education Fund attended a meeting of the Market Risk Advisory Committee for the Commodity Futures Trading Commission. There, AFREF/DPEF staff gave remarks on digital assets, including recommendations to the Committee regarding research and analysis into proper regulatory oversight of the digital assets sector. Recommendations included research into cybersecurity risks associated with crypto platforms and crypto derivatives, as well as a review of due diligence processes conducted by the CFTC and other regulators when CFTC registered entities involved in digital assets are acquired by another firm.
AFREF joined two letters – one to the Internal Revenue Service (IRS) and Department of Treasury, and one to the Consumer Financial Protection Bureau (CFPB) – urging the Biden-Harris Administration to do more to relieve medical debt for tens of millions of people. The letters, signed by more than 60 organizations, include specific executive actions the administration can take to address medical debt.
AFREF and Demand Progress Education Fund submitted comments to the Office of Science and Technology Policy (OSTP) in response to the agency’s request for information regarding the risks, limitations and purported benefits of blockchain technology (including regarding central bank digital currencies), to help inform the government’s research and development agenda on blockchain. The submission raised concerns about the technological limits and risks of blockchain as used for both financial and non-financial applications, as well as a variety of risks, and urged the OSTP to take a more balanced and sober look at blockchain in view of these limitations.