Category Archives: Letters to Regulators

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 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: 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.