Category Archives: Letters to Regulators

Letters to Regulators: Letter to the CFPB Urging for Critical Improvements to a Proposed COVID Loss Mitigation Rule

AFREF and 41 organizations sent comments in response to the CFPB’s proposed COVID loss mitigation rule urging the Bureau to make critical improvements to help avoid unnecessary foreclosures and to facilitate streamlined solutions for borrowers facing COVID-19 hardships that will make it possible for them to keep their homes and provide them with the stability they need to recover and rebuild.

A pair of hands writing on paper with a pen

Letters to Regulators: Letter to the OCC to Scrutinize New Partnerships Between Risky Share Agreement Companies and Banks

AFREF joined our partners in sending a letter calling on the OCC to carefully scrutinize new partnerships between risky Income Share Agreement companies and banks under OCC supervision. Partnerships like the one between Mentorworks and Blue Ridge Bank have the potential to put borrowers at risk by opening the market to a product that is violating the law & harming borrowers.

a green forest with a tornado looming

Letters to Regulators: Letter in Response to FHFA RFI Expressing Concerns About Climate and Natural Risk Management

AFREF and 17 organizations sent a letter in response to FHFA’s RFI on climate and natural risk management detailing our concerns about the disproportionate impact of climate change and natural disasters on borrowers and communities of color and low and moderate income neighborhoods. We provided recommendations for next steps on FHFA’s work on mitigating climate risk and urged FHFA to make sure climate risk mitigation efforts do not cause inadvertent harm to the communities who are already most vulnerable to the adverse effects of climate change and who face the most challenges in accessing and sustaining homeownership.

Letters to Regulators: AFR Education Fund Calls on SEC for Stronger Regulation of Funds in Wake of March 2020 Bailout

The AFR Education Fund sent a letter to the Securities and Exchange Commission responding to a request for comment on regulatory options for money market funds in light of the collapse and bailout of many money market funds during the March 2020 coronavirus financial shock. The letter called for strong new regulatory steps to fix incentives that create financial instability for these products. It also questioned whether additional regulation should be extended to other types of fixed-income investment funds beyond money market funds narrowly defined, as there is evidence that these types of fund arrangements can also contribute to financial instability.

Letter to Regulators: Fill Vacant Inspector General positions

AFR joins a letter to the White House and the Council of the Inspectors General on Integrity and Efficiency (CIGIE), calling on President Biden to nominate individuals to fill the fourteen open inspector general positions by June 1, 2021. Inspectors general are a linchpin of government accountability yet fourteen of the seventy-four total offices of the inspectors general are vacant. The ongoing response to COVID-19 has demonstrated the importance of using all available mechanisms within the federal government to ensure proper oversight and accountability of government programs.

sign for the CFPB outside a building

Letters to Regulators: Letter to the CFPB Re: Renewed Request to Rescind Language in April 1, 2020 CFPB Guidance Allowing CRAs and Furnishers to Exceed FCRA Deadlines for Disputes

AFREF joined our partners in sending a follow-up letter calling on the CFPB to rescind its April 1, 2020 guidance allowing consumer reporting agencies and furnishers to exceed the dispute investigation deadlines under the Fair Credit Reporting Act. In the six months since we sent our last letter, the situation has only gotten worse, with nearly 26,000 more complaints submitted by consumers about delayed or nonexistent responses to credit/consumer reporting disputes. We urged the Bureau to revoke the guidance as soon as possible to prevent further consumer harm.