Letters to Regulators: Letter to OMB on Race and Ethnicity Data Standards
AFREF joined a comment letter to OMB on revising their race and ethnicity data standards.
Category Archives: Education Fund
Letters to Regulators: Letter to the FTC to Ban Non-Compete Clauses
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.
Letters to Regulators: Letter to FHA on 203(k) Rehabilitation Mortgage Insurance Program
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.
Letters to Regulators: EPA RFI on Environmental and Climate Justice Block Grant 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.
Letters to Regulators: Letter to FHFA on the Federal Home Loan Bank System
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.
Letters to Regulators: Letter to the CFPB on Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders
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.
Letter to Regulators: Silicon Valley Bank Failure Demonstrates the Need to Implement Key Executive Pay Rule, Dodd-Frank Section 956
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.
Letters to Regulators: Comment Letter to OMB on Uniform Guidance Relating to Stock Buybacks and Executive Comepensation
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.
Remarks: Written Remarks Regarding Digital Assets Policy Frameworks – Areas for MRAC Review
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.
Letters to Regulators: Letters to the IRS and Treasury and the CFPB on Medical Debt
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.