Letters to Regulators: Letter to FTC in Response to NPRM on Auto Financing
AFR joined a letter to the FTC in response to their Notice of Proposed Rulemaking on auto financing.
Category Archives: Letters to Regulators
Letters to Regulators: Letter to CFPB in Response to Inquiry on Employer-Driven Debt
AFREF joined a letter to the CFPB in response to their inquiry on employer-driven debt.
Letters to Regulators: Comment Letter to the CFPB on Employer-Driven Debt
AFREF sent a letter to the CFPB in response to their Request for Information regarding employer-driven debt.
Letter to Regulators: Comment in Response to ED Notice of Proposed Rulemaking on Prison Education Programs, 90/10 and Change of Ownership
AFREF joined a comment letter in response to the Education Department’s Notice of Proposed Rulemaking on prison education programs, 90/10 and change of ownership.
Letter to Regulators: Letter to Treasury on How to Increase Transparency in the U.S. Treasury Market”
AFREF sent a letter to the Treasury Department on how to increase transparency in the U.S. Treasury market.
Letters to Regulators: A Roadmap for the Federal Reserve
AFREF sent a roadmap for action to the Federal Reserve.
Letters to Regulators: Groups Call On FDIC To Reject Ford Credit’s ILC Charter Application
AFREF joined the National Community Reinvestment Coalition, the National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending in sending a letter to the FDIC saying that Ford Motor Company should be denied deposit insurance for its proposed new Ford Credit industrial loan company (ILC) charter.
Letters to Regulators: Reject TD Bank and First Horizon Bank Proposed Merger
AFREF and CRL led a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank.
Letters to Regulators: Letter to the SEC in Response to Request for Comment on Certain Information Providers Acting as Investment Advisors
AFREF sent a letter to the Securities and Exchange Commission supporting its proposal to treat index providers as investment advisers given the many traits of index providers that resemble investment advice.
Such proposals are necessary as index funds have grown to become a multi-trillion dollar industry but one whose decisions to include or exclude issuers from the indices, and which many fund managers must closely follow, remain opaque and feature a number of conflicts-of-interest.
Letters to Regulators: Environmental, Social, and Governance (ESG) Names and Disclosures for Investment Funds
Americans for Financial Reform Education Fund (AFREF) submitted comments to the Securities and Exchange Commission (SEC) on their proposed rules regarding fund names and required Environmental, Social, and Governance (ESG) disclosures for investment funds and advisers. These proposed rules would prevent the use of misleading