Category Archives: Letters to Regulators

LETTER TO REGULATORS: Broad Opposition to the CFPB’s Plan to Engage in Payday Loan Disclosure Testing

The Americans for Financial Reform and the undersigned consumer, civil rights, community and faith- based organizations oppose the Bureau’s plans to engage in payday loan disclosure testing. We do so in the broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from the harms associated with payday lenders’ practice of making payday loans without reasonable ability-to-repay determinations. New disclosures would only provide a false veneer of protections that payday lenders would use to bolster their opposition to meaningful consumer protections against unaffordable loans.

Letters to Regulators: Comment Letter to the CFPB on the Equal Credit Opportunity Act

AFREF and 47 organizations submitted comments on the CFPB’s RFI on the Equal Credit Opportunity Act (ECOA) and Regulation B. Our comments urged the Bureau to take no action that would weaken the ECOA in any way and consider certain steps to improve and strengthen fair lending protections under ECOA to make it stronger and more effective tool for fighting credit discrimination.

Letter to Regulators: Letter to the Small Business Administration urging them to maintain strong information collection requirements under the Paycheck Protection Program

Americans for Financial Reform Education Fund (AFREF) and Main Street Alliance (MSA) respectfully urge the Small Business Administration (SBA) to maintain the information collection under the Paycheck Protection Program (PPP) new Loan Necessity Questionnaire for recipients and encourage the SBA to support robust supplemental disclosure requirements for PPP recipients.

Letter to Regulators: SEC Should Withdraw Proposed “Finders” Exemption to Broker-Dealer Regulation

By creating a blanket exemption for a broadly defined group of “finders” to effectively act as solicitors and brokers in private investment markets without being subject to any of the requirements on registered broker-dealers as regards disclosure, qualifications, obligations to customers, pricing, record-keeping, business conduct, financial resources, or compliance with FINRA rules, the Commission would abrogate its responsibilities to protect investors and to maintain fair and orderly markets.

Joint Letter: Letter to CFPB Opposing Reorganization of its Division on Supervision, Enforcement and Fair Lending

Americans for Financial Reform Education Fund joined our partners in sending a letter signed by 83 groups opposing the Consumer Financial Protection Bureau’s proposed reorganization of its Division of Supervision, Enforcement and Fair Lending because it would drastically weaken the office’s authority independence, and effectiveness, and leave consumers vulnerable to harm.

Letters to Regulators: Letter to the U.S. Department of Justice Regarding the Bank Merger Competitive Review Guidelines.

Americans for Financial Reform Education Fund submitted a comment letter asking the Department of Justice to protect the public interest from ever larger banks exercising market power to impose higher costs on consumers, reduce the volume or quality of banking services, and from becoming so large that they pose a risk to the entire financial system and real economy.

Letter to Regulators: Letter to the Department of Labor urging it to withdraw a proposal that would impose new burdens and costs on retirement plans.

AFREF submitted a letter to the Department of Labor urging it to withdraw a rule proposal that would impose onerous costs and process requirements on private sector retirement plans when deciding whether and how to vote on matters brought to a vote at public companies’ annual meetings. It will impose costs on retirement savers and undermine advances on corporations’ integration of environmental, social and governance factors, including those that have a material financial impact on long-term investment performance