Category Archives: Letters to Regulators

Letters to Regulators: Letter Asking for Restored Supervisory and Enforcement Tools in Mortgage Servicing Rules

AFREF, NCLC, NFHA and NHLP sent a letter to the CFPB, FRB, FDIC, OCC, NCUA and CSBS asking the agencies to update the April 3, 2020 Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the COVID-19 Emergency and the CARES Act to restore key supervisory and enforcement tools to incentivize servicers to properly handle applications for loss mitigation assistance and require servicers to send loss mitigation notices to borrowers, which are especially critical as forbearances come to an end in the coming months.

Letter to Regulators: Letter to the IRS and Treasury on Tackling Systemic Tax Abuses by the Private Equity Industry

The 18 organizations urge the Internal Revenue Service (IRS) to prioritize rebuilding its auditing and enforcement capabilities in order to tackle systemic tax abuses, including in particular those by the private equity industry. The private equity industry has generated greater untaxed revenues over the past decades by structuring their funds to avoid taxes and through a strategy of misclassifying certain earnings, exploiting tax loopholes like carried interest, and utilizing complex and opaque business structures to shield earnings from IRS scrutiny. We applaud President Biden’s plans to fund the IRS and tax enforcement more robustly and believe that these needed changes are a strong argument for such additional resources.