Letters to Regulators Archives - Page 22 of 54 - Americans for Financial Reform

Letters to Regulators: Comment on the CFPB’s ANPR Regarding Consumer Access to Financial Records

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.

Letters to Regulators: Letter to the CFPB to Prevent Covid Foreclosures

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.

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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

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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.”

Letters to Regulators: Predatory Lending Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

Americans for Financial Reform Education Fund signed onto a predatory lending letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it was inconsistent with the agency’s fundamental charges to ensure safety and soundness, consumer protection, fair lending, and the aims of the Community Reinvestment Act. The letter stated that the OCC did not have the authority to make such a proposal, and that it created an unmistakable and absolute conflict by pressuring banks to finance lenders whose models are driven by unaffordable lending.

Letters to Regulators: Climate Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

Americans for Financial Reform Education Fund signed onto a comment letter, organized by Public Citizen, opposing the OCC’s proposed rule “Fair Access to Financial Services” due to climate concerns. The letter urged the OCC to withdraw the proposal on the basis that it required banks to serve every category of high-risk business, with the express goal of increasing bank lending to risky fossil fuel companies and other polluting sectors, and without regard for strategic or reputational risk. The letter stated that the OCC lacked the legal authority to enact this proposed rule, that banks are acting prudently to exit the fossil fuel industry because of growing climate risk to the sector, and that the OCC should instead scrutinize and curb banks’ involvement with high-emission activities.

Letters to Regulators: Housing Joint Letter Opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services”

Americans for Financial Reform Education Fund signed onto a housing letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it is a perversion of long-held anti-discrimination principles. The letter stated that the OCC appropriated civil rights language to protect market activities, drafted vague and unintelligible standards, undermined the ability of financial institutions to consider important facets of reputational risk in making investment and underwriting determinations, and provided a negligently inadequate 45-day comment period in the midst of the COVID crisis.

Letters to Regulators: Letters to OCC about Oportun’s Application for a National Bank Charter

Americans for Financial Reform Education Fund signs onto two comment letters to the OCC about Oportun’s application for a national bank charter. The letters express several concerns about Oportun’s practices regarding debt collection, lending and Community Reinvestment Act compliance planning. They urge the OCC to condition Oportun’s charter upon substantial improvement of these practices.