Letters to Regulators: Letter to the CFPB Calling for Strengthened Consumer Protections in Final Debt Collection Rules
AFREF joined a letter to the CFPB calling for greater consumer protections in their final debt collection rules.
Category Archives: Letters to Regulators
Letter to Regulators: Letter to the IRS and Treasury on Tackling Systemic Tax Abuses by the Private Equity Industry
The 18 organizations urge the Internal Revenue Service (IRS) to prioritize rebuilding its auditing and enforcement capabilities in order to tackle systemic tax abuses, including in particular those by the private equity industry. The private equity industry has generated greater untaxed revenues over the past decades by structuring their funds to avoid taxes and through a strategy of misclassifying certain earnings, exploiting tax loopholes like carried interest, and utilizing complex and opaque business structures to shield earnings from IRS scrutiny. We applaud President Biden’s plans to fund the IRS and tax enforcement more robustly and believe that these needed changes are a strong argument for such additional resources.
Letters to Regulators: Detailed Letter to CFPB on Proposed COVID Loss Mitigation Rule
AFREF, NCLC, and NHLP submitted detailed comments to the CFPB urging the Bureau to strengthen its make necessary improvements to its COVID loss mitigation proposal to protect the most vulnerable borrowers and strengthen protections against foreclosures.
Letter to the Regulators: The SEC Should Not Allow For More Leveraged Volatility ETFs
AFR submitted a comment letter to the Securities and Exchange Commission urging the Commission not to approve any additional leveraged ETF based on the Chicago Board of Exchange (CBOE) Volatility Index of the S&P 500 (“VIX”). The letter raises important concerns about not only the
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.
Letters to Regulators: Letter Detailing Ways to Improve Protections for Retail Investors
AFREF joined a letter to the Department of Labor detailing ways to improve protections for retail investors.
Letters to Regulators: Request that CFPB Prohibit Credit Reporting of Rent Arrears Incurred During COVID-19 Pandemic
AFREF joined a letter to the CFPB requesting they prohibit credit reporting of rent arrears incurred during the COVID-19 pandemic
Letters to the Regulator: Letter to the SEC on Conditional Substituted Compliance for Non US Swap Dealers and Participants
AFR submitted a comment letter to the Securities and Exchange Commission supporting the Commission’s proposals to require foreign security-based swap dealers and participants to abide by the SEC’s own set of capital and initial margin requirements as opposed to the less stringent Basel capital requirements.
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.
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.