Category Archives: Letters to Regulators

Letters to the Regulators: AFREF Comments in Support of Homeowner Protections in FHA Note Sales, Against Corporate Consolidation of Housing

AFR-EF submitted comments on the HUD’s Single Family Home Sale Program in support of improved borrower protections for homeowners impacted by FHA note sales. AFR-EF also called on the FHA to change practices that allow private equity and other corporate landlords access to large note pools, highlighting the negative impacts on homeowners and their neighborhoods.

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Letter to the Regulators: AFREF Comments to Department of Treasury Regarding Request for Information on AI in Financial Services

AFREF submitted a comment regarding a request for information on uses, opportunities, and risks of artificial intelligence in the financial services sector. The comment notes that while artificial intelligence (AI), including machine learning and generative models, could potentially transform the financial services industry, insufficiently robust AI regulatory oversight and supervision can harm consumers by amplifying discriminatory patterns in credit markets, increasing consumer costs, and creating barriers to accessible credit. To address these harms, federal regulators should pursue a rights-based and not solely a risk-based approach.

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Letters to the Regulators: AFREF and CRL submit comment demonstrating structural racism roots of racial disparities in medical debt

Americans for Financial Reform Education Fund and the Center for Responsible Lending support the rule to prohibit creditors and consumer reporting agencies from using medical debt information for credit eligibility determinations. The rule is essential to protect families from the negative impacts of medical debt on their health and their finances. But the rule is especially important to protect Black, Latine, and other people of color who are more likely to have medical debt burdens.

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Letters to the Regulators: AFREF Comment to SEC/FinCEN on Customer Identification Programs for Private Funds and Venture Capital

The Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission and the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) supporting the proposal to require the $125 trillion in Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (mainly Venture Capital) to implement Customer Identification Programs to better understand who the beneficial owners of their funds are.

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Letters to the Regulators: Letter to the Federal Housing Finance Agency in Support of the Title Acceptance Pilot Program

Americans for Financial Reform Education Funded joined with the National Consumer Law Center, the Consumer Federation of America, and other advocacy groups to express our support for recent announcements from Fannie Mae and Freddie Mac, reflecting their intention to explore carefully-crafted pilot programs aimed at reducing closing costs for homeowners–specifically, a “title acceptance” pilot program.

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Letters to the Regulators: Letter to the Public Company Accounting Oversight Board in Support of a Public Reporting Requirement

AFREF and 11 organizations submitted a comment letter to the Public Company Accounting Oversight Board (PCAOB) in support of a proposal to require public accounting firms to publicly report specified firm- and engagement-level metrics. If finalized, these metrics would provide investors, audit committees, and other stakeholders critical information to compare audit firms, make better-informed decisions, and enhance auditor accountability.

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