Category Archives: Letters and Statements

A pair of hands writing on paper with a pen

Letters to Regulators: Letter Urging Financial Regulators to Consider Fair Lending Risks in Use of Artificial Intelligence

AFREF and 22 organizations submitted comments in response to the regulators’ Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning, urging the financial regulators to consider fair lending risks of using artificial intelligence and machine learning and enact safeguards to prevent disproportionate adverse impacts from the use of AI/ML models.

A pair of hands writing on paper with a pen

Letters: Principles for Equitable Zoning Reform

AFR joined over 100 groups in sending a letter urging the Biden administration to ensure that any zoning reform incentives or requirements actually do the job of opening up exclusionary areas to more economic and racial diversity; do not further the displacement of low-income communities and communities of color, do not result in the loss of affordable housing, and do not further entrench profit-driven commodification of housing. Federal action to eliminate exclusionary zoning has the potential to expand racial and economic justice, but, if not crafted carefully, the effort could be ineffective or even harmful to communities of color.

Letters to Regulators: Letter Asking for Restored Supervisory and Enforcement Tools in Mortgage Servicing Rules

AFREF, NCLC, NFHA and NHLP sent a letter to the CFPB, FRB, FDIC, OCC, NCUA and CSBS asking the agencies to update the April 3, 2020 Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the COVID-19 Emergency and the CARES Act to restore key supervisory and enforcement tools to incentivize servicers to properly handle applications for loss mitigation assistance and require servicers to send loss mitigation notices to borrowers, which are especially critical as forbearances come to an end in the coming months.

Letter to Regulators: The Fed must recognize its own regulatory failures and take action in the wake of Archegos

Americans for Financial Reform Education Fund wrote the Fed to express concerns over the blow-up of the Archegos family fund. This incident reveals both the dangers of excessive leverage at private funds, and the failure of banking regulators, including the Federal Reserve, to properly regulate bank interactions with such funds. To address these issues, the Federal Reserve must investigate its own regulatory failures in this case and publicly disclose the lessons learned from this investigation, and must also work with the Financial Stability Oversight Council to address the risks of excessive leverage at private funds.