Category Archives: Letters to Regulators

Letters to the Regulators: AFREF Comment to SEC/FinCEN on Customer Identification Programs for Private Funds and Venture Capital

The Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission and the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) supporting the proposal to require the $125 trillion in Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (mainly Venture Capital) to implement Customer Identification Programs to better understand who the beneficial owners of their funds are.

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Letters to the Regulators: Letter to the Federal Housing Finance Agency in Support of the Title Acceptance Pilot Program

Americans for Financial Reform Education Funded joined with the National Consumer Law Center, the Consumer Federation of America, and other advocacy groups to express our support for recent announcements from Fannie Mae and Freddie Mac, reflecting their intention to explore carefully-crafted pilot programs aimed at reducing closing costs for homeowners–specifically, a “title acceptance” pilot program.

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Letters to the Regulators: Letter to the Public Company Accounting Oversight Board in Support of a Public Reporting Requirement

AFREF and 11 organizations submitted a comment letter to the Public Company Accounting Oversight Board (PCAOB) in support of a proposal to require public accounting firms to publicly report specified firm- and engagement-level metrics. If finalized, these metrics would provide investors, audit committees, and other stakeholders critical information to compare audit firms, make better-informed decisions, and enhance auditor accountability.

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Letters to the Regulators: Group response to Request for Information on Consolidation in Healthcare Markets

AFREF and 96 organizations and individuals concerned about the harmful impacts of transactions that affect consolidation in health care submitted comments responding to a Request For Information from the Department of Justice, Federal Trade Commission, and Department of Health & Human Services, calling for action to curb the abuses of private equity and safeguard the ability of doctors to deliver quality care to all patients and achieve equitable health outcomes.

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Letters to the Regulators: AFREF response to Request for Information on Consolidation in Healthcare Markets

AFREF submitted its own comment in response to a Request For Information from the Department of Justice, Federal Trade Commission, and Department of Health & Human Services. The comment focuses on transactions by private equity (PE) funds which, by treating health care facilities and companies as financial instruments, have inflicted damage on health care businesses, communities, and individuals.

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Letters to the Regulators: AFR Submits Filing Opposing Capital One-Discover Merger for Failing to Meet Bank Merger Act Requirements

AFREF submitted a second brief with the Office of the Comptroller of the Currency and Federal Reserve calling on the banking regulators to reject the proposed Capital One-Discover merger. The proposed Capital One-Discover merger would have significant anti-competitive impacts that would harm consumers and communities. The merger also fails to meet the requirements and conditions of the Bank Merger Act and Bank Holding Company Act. It fails to meet the convenience and needs of communities by raising consumer credit card costs, having a record of misleading marketing and aggressive debt collection, and closing two-thirds of its branches over the past 15 years.

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Letter to the Regulators: Emphasizing the Urgent Need to Implement Key Executive Pay Rule, Dodd-Frank Act Section 956

AFREF and Public Citizen led a coalition letter urging the six relevant agencies to implement section 956 of the Dodd-Frank Act, which requires them to promulgate a rule banning incentive-based executive pay that incentivizes inappropriate risk-taking. A year after the 2023 banking crisis — and almost fourteen years after the statutory mandate was enacted — we do not have a rule to protect consumers, depositors, and the public from executives’ excessive risk-taking.

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Letters to the Regulators: Letter to the National Association of Insurance Commissioners Outlining the Need for Public, Transparent, and National Data Collection on the Property and Casualty Insurance Market

AFR joined the Consumer Federation of America and 18 other civil rights, housing, and climate advocacy groups in writing this letter to the National Association of Insurance Commissioners regarding the need for a public, transparent, and national data collection on the property and casualty insurance market.

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