Category Archives: Letters to Regulators

Letters to the Regulators
Letter in Support of Urging Rulemaking for Tenant Protections Under the Equal Credit Opportunity Act

AFREF submitted a comment letter supporting the National Consumer Law Center’s petition urging the Consumer Financial Protection Bureau to define residential real estate leases as “credit” and landlords as “creditors” under the Equal Credit Opportunity Act. This petition for rulemaking addresses important components of the ongoing legacy of structural racism in credit and residential housing for people of color seeking rental leases to shelter their families and build a foundation for economic stability.

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Letters to the Regulators
AFREF and Allies Commend FDIC Effort to Regulate Industrial Loan Banks

AFREF, Consumer Federation of America, Prof. Arthur Wilmarth, Jr. and Center for Responsible Lending submitted a comment to the Federal Deposit Insurance Corporation supporting the effort to strengthen the oversight of industrial loan companies (ILCs). The proposed rule would heighten scrutiny of new ILCs or attempts to take over existing ILCs that will more fully consider the unique risks of these banks.

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Letters to the Regulators
Letter in Support of Providing Relief and Protections Under the Fair Credit Reporting Act to Victims of Coerced Debt

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter supporting a petition from the National Consumer Law Center and the Center for Survivor Agency and Justice asking the Consumer Financial Protection Bureau to provide relief to victims of coerced debt under the Fair Credit Reporting Act. The petition would provide critically needed relief to victims of coerced debt (a form of economic abuse) and further protect people who are survivors of intimate partner violence.

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Photo by Tom Rumble on Unsplash


Memo to Banking Regulators Recommending Further Guidance on Climate-Related Financial Risk Mitigation, Fair Lending, & Climate Investment Opportunities

AFREF authored a memo endorsed by nine partner organizations, which highlights opportunities for financial institutions to mitigate climate-related financial risk in a way that doesn’t violate fair lending and supports communities while building resilience through Community Reinvestment Act (CRA) and Inflation Reduction Act (IRA) opportunities.

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Letters to the Regulators
AFREF Submitted Comments to the Federal Trade Commission and Department of Justice on the Negative Impacts of Serial Acquisitions and Roll-Up Strategies

AFREF submitted comments to the Federal Trade Commission and Department of Justice on serial acquisitions and roll-up strategies and their impact on competition, the market, workers, consumers, and communities. Decades of unchecked mergers, driven largely by private equity, have consolidated economic power and raised consumer prices, suppressed workers’ wages, undermined the ability to form and sustain small businesses, and sapped vitality from our communities. These negative impacts have disproportionately harmed people of color, women, and people with limited English proficiency as individuals, families, and communities.

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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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