Category Archives: Letters to Regulators

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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Letters to the Regulators: Letter in Support of Urging Rulemaking for Tenant Protections Under the Equal Credit Opportunity Act

AFREF submitted a comment letter supporting the National Consumer Law Center’s petition urging the Consumer Financial Protection Bureau to define residential real estate leases as “credit” and landlords as “creditors” under the Equal Credit Opportunity Act. This petition for rulemaking addresses important components of the ongoing legacy of structural racism in credit and residential housing for people of color seeking rental leases to shelter their families and build a foundation for economic stability.

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Letters to the Regulators: AFREF and Allies Commend FDIC Effort to Regulate Industrial Loan Banks

AFREF, Consumer Federation of America, Prof. Arthur Wilmarth, Jr. and Center for Responsible Lending submitted a comment to the Federal Deposit Insurance Corporation supporting the effort to strengthen the oversight of industrial loan companies (ILCs). The proposed rule would heighten scrutiny of new ILCs or attempts to take over existing ILCs that will more fully consider the unique risks of these banks.

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Letters to the Regulators: Letter in Support of Providing Relief and Protections Under the Fair Credit Reporting Act to Victims of Coerced Debt

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter supporting a petition from the National Consumer Law Center and the Center for Survivor Agency and Justice asking the Consumer Financial Protection Bureau to provide relief to victims of coerced debt under the Fair Credit Reporting Act. The petition would provide critically needed relief to victims of coerced debt (a form of economic abuse) and further protect people who are survivors of intimate partner violence.

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Letters to the Regulators: AFREF Submitted Comments to the Federal Trade Commission and Department of Justice on the Negative Impacts of Serial Acquisitions and Roll-Up Strategies

AFREF submitted comments to the Federal Trade Commission and Department of Justice on serial acquisitions and roll-up strategies and their impact on competition, the market, workers, consumers, and communities. Decades of unchecked mergers, driven largely by private equity, have consolidated economic power and raised consumer prices, suppressed workers’ wages, undermined the ability to form and sustain small businesses, and sapped vitality from our communities. These negative impacts have disproportionately harmed people of color, women, and people with limited English proficiency as individuals, families, and communities.

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