The Americans for Financial Reform Education Fund (AFREF), along with 37 labor unions, investors, and advocacy organizations, submitted a comment letter to the Federal Deposit Insurance Corporation (FDIC) in support of their proposal to strengthen regulations under the Change in Bank Control Act (CBCA).
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.
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.
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.
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.
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.
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.
AFR-EF submitted comments on the HUD’s Single Family Home Sale Program in support of improved borrower protections for homeowners impacted by FHA note sales. AFR-EF also called on the FHA to change practices that allow private equity and other corporate landlords access to large note pools, highlighting the negative impacts on homeowners and their neighborhoods.
AFREF submitted a comment regarding a request for information on uses, opportunities, and risks of artificial intelligence in the financial services sector. The comment notes that while artificial intelligence (AI), including machine learning and generative models, could potentially transform the financial services industry, insufficiently robust AI regulatory oversight and supervision can harm consumers by amplifying discriminatory patterns in credit markets, increasing consumer costs, and creating barriers to accessible credit. To address these harms, federal regulators should pursue a rights-based and not solely a risk-based approach.
Americans for Financial Reform Education Fund and the Center for Responsible Lending support the rule to prohibit creditors and consumer reporting agencies from using medical debt information for credit eligibility determinations. The rule is essential to protect families from the negative impacts of medical debt on their health and their finances. But the rule is especially important to protect Black, Latine, and other people of color who are more likely to have medical debt burdens.