Category Archives: Letters to Regulators

Letters to the Regulators: AFR and Public Citizen Letter to the New York State Department of Financial Services Proposal to Evaluate Nonbank Mortgage Lenders

Public Citizen and Americans for Financial Reform Education Fund submitted a comment to the New York State Department of Financial Services (DFS) on its proposal to evaluate nonbank mortgage lenders in New York based on their performance in meeting the credit needs of the communities where they operate, including needs related to increasing climate risks on housing

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Letters to the Regulators: Letter to the FTC in Support of Collecting Information on Large-Scale Single Family Home Investors

Americans for Financial Reform Education Fund submitted a comment in support of the Federal Trade Commission’s proposed 6(b) study of large-scale single family home investors and the Commission’s plan to publicly disseminate information about homes owned by “mega investors,” defined as entities that own over 1,000 single family rental homes. 

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Letters to Regulators: Letter to the Department of Treasury’s Federal Insurance Office Urging the Swift Release of Climate Change and Insurance Affordability Data

AFREF and 36 partners led a letter urging the Department of Treasury’s Federal Insurance Office (FIO) to swiftly release the homeowner insurance data that the National Association of Insurance Commissioners collected from over 330 insurers representing over 80% of the property and casualty market while also urging FIO to swiftly release a robust report analyzing the data.

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Letter to the Regulators: Letter to the SEC Supporting PCAOB’s Standardized Firm and Engagement Metrics

Americans for Financial Reform Education Fund, joined by 9 signatories, submitted a letter to the Securities and Exchange Commission strongly endorsing the Public Company Accounting Oversight Board’s (PCAOB) proposed standards. The standards would require firms to disclose standardized and comparable metrics that facilitate cross-firm comparisons and assessments of audit quality, providing critical data for investors to make informed decisions. The letter highlights that requiring consistent and comparative metrics will reduce opportunistic disclosures, simplify audit committee oversight, and foster a data-driven approach to regulation and audit quality.

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Letters to Regulators: NCUA Budget for 2025-2026 Should Dedicate Funding to Support Climate Financial Risk Mitigation and Climate Resilience Opportunities for Credit Unions & Their Members

Americans for Financial Reform Education Fund led and submitted a letter to the National Credit Union Administration (NCUA) on the agency’s draft 2025-2026 budget. It urges NCUA to appropriately dedicate funding to support credit unions on climate-related financial risk mitigation, climate resilience, and providing safe, equitable

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Letters to the Regulators: Letter to the SEC in Opposition to Private Credit Exchange Traded Fund

The Americans for Financial Reform Education Fund led a letter of 10 signers urging the Securities and Exchange Commission (SEC) to reject an application for a novel exchange traded fund (ETF) that would allow retail investors to invest in the $1.7 trillion private credit market. Several larger institutional investors have already taken losses in the private credit market and the letter warns how the presence of an institutional investment manager still fails to mitigate concerns around valuation, conflicts of interest, and suitability.

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News Release: Labor, Advocates Push for Limits on Asset Manager Influence Over U.S. Banks

Today, 38 labor unions, investors, and advocates submitted a letter to the Federal Deposit Insurance Corporation (FDIC) in support of a proposed rule that would increase oversight of asset managers with substantial voting power in banks. The proposal would bolster FDIC oversight when asset managers gain control of over 10 percent of voting securities of bank holding companies with FDIC-supervised subsidiaries.

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