Category Archives: Letters to Regulators

the front side of an apartment building

Letters to Regulators: Letter to the OMB Opposing Proposed Redefinition of Metropolitan Statistical Areas

AFREF joined a letter opposing the Office of Management and Budget’s proposal to redefine metropolitan statistical areas. The OMB’s proposal would result in a substantial loss for undeserved and under-invested communities by reducing the number of low and moderate income census tracts eligible for Community Reinvestment Act credit and decreasing the number of banks providing Home Mortgage Disclosure Act data, which may pose increased challenges to fair lending enforcement.

lawyer signing a document Photo by Helloquence on Unsplash

Letters to Regulators: Letter to HUD Urging for Protections for FHA Borrowers

AFREF joined our partners to send a letter urging HUD to take further steps to protect FHA borrowers facing COVID-related hardships form foreclosure, including requiring servicers to communicate the availability of several loss mitigation options, providing guidelines for contacting borrowers before the end of a forbearance, and collect performance data on COVID-19 loss mitigation options and make this information available to the public.

a pile of credit cards

Letters to Regulators: Letter to NCUA Opposing Proposed Change to Overdraft Policy

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.

Federal reserve board

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.