Category Archives: Letters to Regulators

Letters to Regulators: Letter From 29 Signers to the SEC on Passing Strong Final Rules on Private Fund Advisers to Protect Investors and the Financial System

AFREF led a letter with 29 signers to the Securities and Exchange Commission reiterating the important need to pass a strong set of final rules related to requiring private fund advisers to disclose a complete breakdown of fees/expenses, assumptions used to calculate returns, and the existence of side letters to investors.

The letter is also urging the SEC to finalize a strong set of rules related to requiring private fund advisers over a certain size to report more detailed information about their holdings confidentially to the SEC so that the SEC and other financial regulatory agencies have much greater insight into the risks in the $21 trillion private fund space where there is currently little visibility in order to better safeguard the financial system.

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Letter to IOSCO on Voluntary Carbon Market Oversight

The International Organization of Securities Commissions (IOSCO) seeks comment on a Voluntary Carbon Markets Discussion Paper issued to advance the discussion about what sound and efficient Voluntary Carbon Markets should look like and what role financial regulators may play in promoting integrity in those markets. Americans for Financial

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Letters to Regulators: Letter to ED on IDR Proposed Rulemaking

AFREF joined a letter to the Dept. of Education applauding the Department for the significant positive impact its proposed changes to the IDR rules could have on student loan borrowers.  The proposed rule has the ability to substantially reduce monthly and lifetime payments for millions of borrowers, raise the threshold for protected non-discretionary income, lower the share of discretionary income borrowers have to pay, waive unpaid interest, and decrease time to cancellation.

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SEC Building

Letters to Regulators: SEC Climate Disclosure – New Developments February 2023

We are writing on behalf of Public Citizen, Americans for Financial Reform Education Fund, and Sierra Club to supplement the information provided in previous comments we submitted. The purpose of this letter is to highlight a number of recent developments that further strengthen the rationale for the proposed rule.

As explained in our attached summary of developments related to climate-related financial risk, dramatic changes ushered in by the Inflation Reduction Act, the Russian invasion of Ukraine, and global market trends more generally, are accelerating a rapid transformation in the investment landscape.

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A book titled "Consumer Protection" on a desk with a gavel resting on top

Letters to Regulators: Letter to the FTC on Junk Fees

AFREF and partners led a letter to the FTC urging it to use its rulemaking authority to protect American consumers from junk fees and put money back into our pockets. Millions of consumers have expressed outrage at the imposition of service fees for live event tickets, “amenity” or “resort” fees charged by hotels, endless surprise rental car fees, hidden internet and cell phone charges, junk fees in the financial sector, and more. The federal government has taken a holistic approach to this problem, including the White House Competition Council, the Consumer Financial Protection Bureau (CFPB), the Department of Transportation (DOT) and now the FTC. 

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News Release: OCC Should Follow CFPB Lead in Drawing Tough Line on Repeat Offenders

The nation’s big-bank regulator, the Office of the Comptroller of the Currency, should help broaden and extend a crackdown on financial institutions that repeatedly violate the law – notably Wells Fargo – with all the tools at its disposal. Comptroller Michael Hsu is speaking on the problem of “too big to manage” today. The speech comes about a month after the Consumer Financial Protection Bureau ordered Wells to pay $3.7 billion over widespread mismanagement of auto loans, mortgages, and deposit accounts, and promised to work with other federal regulators to find durable solutions to its constant violations of the law.

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