Category Archives: Letters to Regulators

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.

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.

Letters to the Regulators: Letter in Support of Financial Crimes Enforcement Network’s Notice of Proposed Rulemaking to Establish Anti-Money Laundering Regulations for Certain Residential Real Estate Transfers

AFR-EF joined with the FACT Coalition and 35 organizations committed to affordable housing to support the Financial Crimes Enforcement Network (FinCEN) of the United States (U.S.) Department of the Treasury (Treasury)’s notice of proposed rulemaking (NPRM) to establish anti-money laundering regulations for certain residential real estate transfers. Aspiring homebuyers and renters alike simply should not be forced to compete with anonymous entities – including those concealing criminal or other abusive activity – for limited affordable housing options at ever-inflated prices.

Letters to the Regulators: AFR Submits Filing in Opposition to Capital One Financial Corporation’s Acquisition of Discover Financial Services

AFREF wrote a letter in opposition to the proposed Capital One Financial Corporation acquisition of Discover Financial Services, which would substantially erode competition and disadvantage consumers and merchants. The transaction would create the nation’s biggest credit card lender, one of the biggest banks, and a powerful vertically integrated payments network combined with a branch bank and credit card issuer.

Letter to the Regulators: Comment to Treasury FinCEN Supporting Greater Anti-Money Laundering Screening for Registered Investment Advisers, Exempt Reporting Advisers, and Family Offices

Americans for Financial Reform Education Fund wrote a comment supporting the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposals to require additional anti-money laundering and countering of financial terrorism (CFT) requirements for Registered Investment Advisers (RIA). We also encourage FinCEN to jointly propose rulemaking with the Securities and Exchange Commission (SEC) to require the collection of beneficial ownership as well as the creation of a Customer Identification Program (CIP). 

Letters to Regulators: IOSCO Should Explicitly Acknowledge That Environmental and Social Integrity Are Critical Components of the Market Integrity of Carbon Credits

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter on The Board of the International Organization of Securities Commissions (IOSCO)’s Consultation Report outlining a proposed set of Good Practices to promote the integrity and orderly functioning of Voluntary Carbon Markets (VCMs).  IOSCO has

Letters to the Regulators: Letter in Support of Developing a Financial Inclusion Strategy

Americans for Financial Reform Education Fund (AFREF) sent a letter to the Treasury Department outlining principles, scope, and direction for the department’s development of a financial inclusion strategy.  Developing a financial inclusion strategy is long-overdue and a necessary step to understand and begin to address the contributions of inequitable access to financial products and services for disadvantaged communities to the persistent racial economic inequality in the United States.