Letters to Regulators Archives - Americans for Financial Reform

Letters to Regulators: EPA Should Continue to Develop Greenhouse Gas Reduction Fund Guidance that Delivers Tangible Benefits to Low-Income and Disadvantaged Communities Across the Country

May 12, 2023 Americans for Financial Reform Education Fund (AFREF) submitted an environmental justice advocates comment letter signed by Public Citizen and WE ACT for Environmental Justice to the Environmental Protection Agency (EPA) on its Implementation Framework for the Greenhouse Gas Reduction Fund. The Implementation

Letters to Regulators: Letter to CMS on Proposed Rule on Ownership of Nursing Facilities

AFREF submitted a comment to the Centers for Medicare and Medicaid Services (CMS) on their proposed rule to require the disclosure of important information regarding the ownership and control of nursing facilities, including when an owning or managing entity is a private equity (PE) company or a Real Estate Investment Trust (REIT).

Private equity and healthcare are incompatible and AFREF states in the letter that the current lack of transparency in ownership of facilities exacerbates the problem and shields owners and investors from accountability for the performance of the businesses they own and welcomes the disclosure rule.

Letters to Regulators: Letter Supporting CFPB Safe Harbor for Credit Card Late Fees

AFREF joined a comment letter that strongly supports the CFPB’s proposed safe harbor of $8 for credit card late fees. The CFPB provided ample evidence that this amount is fair, reasonable, and proportional to the costs incurred by issuers for late payments.

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Letters to Regulators: Letter to OMB on Race and Ethnicity Data Standards

AFREF joined a comment letter to OMB on revising their race and ethnicity data standards.

Letters to Regulators: Letter to CMS on Disclosures of Ownership and Additional Disclosable Parties Information

AFREF submitted a letter with partner organizations expressing a mutual concern about the lack of transparency regarding the ownership and control of nursing facilities that serve Medicare and Medicaid beneficiaries.

Letters to Regulators: FTC Should Update its Green Guides to Prevent Greenwashing in Investment and Financial Services, Particularly for Carbon Offsets-Related Claims

Americans for Financial Reform Education Fund (AFREF) submitted two letters in response to the Federal Trade Commission (FTC)’s request for comment on updates to its ‘Green Guides’ for the Use of Environmental Marketing Claims. The Guides were last revised in 2012. AFREF joined a coalition

Letters to Regulators: Letter to the FTC to Ban Non-Compete Clauses

AFREF joined a letter led by the Open Markets Institute and supported by 50 labor and public interest groups urging the Federal Trade Commission (FTC) to ban non-compete clauses as well as functionally equivalent restraints such as training repayment agreement provisions (or TRAPs), for all workers.

Letters to Regulators: Letter to FHA on 203(k) Rehabilitation Mortgage Insurance Program

AFREF joined partner organizations to comment on the FHA’s 203(k) Rehabilitation Mortgage Insurance Program, a program that provides critical financing for low- and moderate-income people seeking to purchase a home in need of repairs. The comment letter details a number of changes that would increase participation in the program.

Letters to Regulators: EPA RFI on Environmental and Climate Justice Block Grant Program

AFREF submitted a comment letter in response to the Environmental Protection Agency’s request for information for the Environmental and Climate Justice Block Grant Program (ECJ Program), which provides funding for financial and technical assistance to carry out environmental and climate justice activities to benefit disadvantaged communities. The letter highlights the need for the ECJ Program to minimize barriers for the most climate-vulnerable applicants, prioritize the needs and perspectives of all underrepresented or historically marginalized community members, and prioritize projects that combat the harmful effects of bluelining by financial service providers.

Letters to Regulators: Letter to FHFA on the Federal Home Loan Bank System

AFREF led 14 organizations in the housing, consumer protection, climate, civil rights, and community investment spaces, in a letter to the Federal Housing Finance Agency regarding the Federal Home Loan Bank system, arguing for expanded contributions to affordable housing to justify the public investment in the system, and for the system to undertake a number of initiatives to support members in reducing their climate risk and climate vulnerability.