AFR Ed Fund and 230 consumer, civil and human rights, labor, community and legal services organizations from all 50 states and the District of Columbia submitted comment on the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed debt collection rules.
Letter to Regulators: Joint Letter to CFPB on Debt Collection NPRM’s failure to protect student loan borrowers from abusive practices
AFR Ed Fund and thirty-three other organizations submitted the following comments in response to the Consumer Financial Protection Bureau (CFPB)’s notice of proposed rulemaking (NPRM) on Debt Collection Practices (Regulation F).
On September 18, 2019, 43 organizations submitted a comment letter to the CFPB about the need for greater protections for Limited English Proficient (LEP) consumers in the debt collection process.
On September 10, 2019, 17 civil rights, consumer and housing advocacy organizations sent a letter to the CFPB addressing QM and urging the Bureau to take additional steps to preserve access to affordable homeownership with adequate consumer protections in place.
On July 23, 2019, AFR Education Fund submitted a letter to the U.S. Securities and Exchange Commission (SEC) opposing a proposal that would create exemptions that would permit U.S. banks – and international banks active in the U.S. market – to do large-scale derivatives dealing in the U.S. without being designated as derivatives dealers under Dodd-Frank Act rules.
AFR wrote a letter to the Federal Reserve Board on a proposal that would liberalize the criteria the Board uses to determine control of a bank. The definition of “control” is critical as it determines whether entities with ownership and influence over banks will be designated as bank holding companies and subject to the appropriate regulation.
FHA mortgages play a crucial role in providing and maintaining access to affordable and sustainable homeownership for low- and moderate-income families and communities of color. If the Loan Sale Program continues in its current unregulated form, FHA borrowers and their communities remain at risk of further harm from non-compliant servicers and private equity loan purchasers. It is crucial that HUD implement strong protections both before and after loans are sold to prevent needless borrower displacement and neighborhood instability.
AFR Ed Fund and six other organizations submitted these comments in response to the Department of Housing and Urban Development (HUD)’s advance notice of proposed rulemaking (ANPR) on the FHA Single Family Loan Sale program. View or download pdf of the letter here.
The proposed loophole-ridden rules let investors to reap tax benefits for investments outside of the Opportunity Zones, compounding the program’s tendency to invest in booming areas that drive up housing costs and displace lower-income residents of color.
Developing clear and appropriate standards for the servicing taxonomy will help ensure that servicers are properly held accountable for non-compliance with FHA’s requirements. It promises to improve the quality of FHA servicing, which in turn will benefit homeowners and the Mutual Mortgage Insurance (MMI) fund. HUD must ensure that its taxonomy tool encompasses these loss mitigation regulations and allows for borrower input into servicer performance in order to truly gauge whether loss mitigation is working for neighborhoods and for the MMI fund.