AFREF joined a letter to FHFA on the importance of accurate and reliable appraisals and putting in place safeguards to protect against improper valuations and racial discrimination.
AFR Education Fund joined a letter to CFPB acting director Dave Uejio that highlighted actions the Bureau can take to address systemic discrimination in the credit markets. The letter outlined issues the Bureau can address immediately and in the long term in line with its focus on racial equity.
AFR Ed Fund joined our colleagues to send a letter opposing the National Credit Union Administration’s proposal to permit federal credit unions to leave negative account balances open for longer than the current limit of 45 days without any limits on overdrafts, overdraft fees, or NSF fees that can be assessed during this period. This proposal fails to consider the substantial risks it poses on credit union members who are facing economic challenges during the pandemic by exposing them to additional fees that only compound their financial distress.
Letters to Regulators: Letter in Response to the Federal Reserve Board’s ANPR on the Community Reinvestment Act
Americans for Financial Reform Education Fund organized a letter to the Federal Reserve Board (FRB) in response to their advanced notice of proposed rule making (ANPR) on the Community Reinvestment Act (CRA). The letter outlined a number of guiding principles and approaches to ensure that any changes to the CRA framework would be limited to measures that will increase equity in bank investments and access to sustainable, wealth-building credit in underserved communities as the statute intended.
AFR joined a letter with our partners The National Consumer Law Center, Center for Responsible Lending, Consumer Action, Consumer Federation of America, and USPIRG commenting on the CFPB’s Advanced Notice of Proposed Rulemaking regarding consumer access to financial records. The letter responded to several questions from the CFPB to assist in developing a proposed rule to implement Section 1033 of the Dodd Frank Wall Street Reform and Consumer Protection Act. It called for a rule that would ensure control and protection for consumers accessing their own account data.
AFREF joined a letter urging the CFPB to take immediate action to prevent a wave of Covid-19-related foreclosures, likely to be concentrated in low-income communities and communities of color.
Letters to Regulators: Joint Letter Opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program
AFR Education Fund signed onto a letter opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program. The letter stated that the proposal cannot achieve its goal of providing a solution for veteran borrowers’ COVID hardships, and urged the VA to revise the proposal to align with existing programs at FHA, USDA, and the Government Sponsored Enterprises. Specifically, the letter stated that the VA should not require monthly payments, funds should not accrue interest, access to the program should be streamlined, and the program should not have a limited time window for relief.
Letter to Regulators: Letter Calls on Banking Agencies to Withdraw Proposed Rule on Supervisory Guidance
AFR Education Fund wrote a letter to banking regulators calling on them to withdraw a proposed rulemaking on the role of supervisory guidance. The letter criticized the new rule as unnecessary and potentially harmful, since it could limit the ability of bank supervisors to take
Letters to Regulators: Letter to the SEC on Proposal to Modernize Shareholder Reports, Disclosures, and Fees
The Americans for Financial Reform Education Fund (AFREF) appreciates the opportunity to comment on the above referenced proposed rule (“the Proposal”) by the Securities and Exchange Commission (the “SEC” of the “Commission”) concerning the simplification and streamlining of the most useful information and fees to
Letters to Regulators: Joint Letters Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”
Americans for Financial Reform Education Fund signed onto several letters opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.”