Category Archives: Letters to Regulators

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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.

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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.

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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.

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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.

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A book titled "Consumer Protection" on a desk with a gavel resting on top

Letters to Regulators: Letter Opposing the PCAOB’s Rushed Rule Weakening Auditor Independence Standards

Americans for Financial Reform Education Fund signs onto a letter from Consumer Federation of America opposing the PCAOB’s proposal to weaken auditor independence standards. The proposed rule will undermine investors’ faith in the reliability of financial disclosures, and risk the integrity of our capital markets. Furthermore, the PCAOB has abused process by adopting these changes without opportunity for public comment and hurrying the SEC approval process without justification. The undersigned urge the SEC to deny the requested rule change.

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Letters to Regulators: Letter Urging HUD to Take Action to Protect Borrowers in Upcoming LIBOR Transition

Americans for Financial Reform Education Fund, Center for Responsible Lending, National Consumer Law Center, National Fair Housing Alliance, and Student Borrower Protection Center sent a joint letter urging HUD to transition to the Secured Overnight Financing Rate (SOFR) and share its LIBOR transition plan as soon as possible. This transition plan should include providing direction to housing counselors about the process and a targeted outreach plan to provide borrowers and all stakeholders with timely, accurate information so that they know what to expect in the months to come. 

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LETTER TO REGULATORS: Broad Opposition to the CFPB’s Plan to Engage in Payday Loan Disclosure Testing

The Americans for Financial Reform and the undersigned consumer, civil rights, community and faith- based organizations oppose the Bureau’s plans to engage in payday loan disclosure testing. We do so in the broader context of the Bureau’s having repealed much-needed substantive ability-to-repay protections without basis and in light of the overwhelming evidence that disclosures will not protect consumers from the harms associated with payday lenders’ practice of making payday loans without reasonable ability-to-repay determinations. New disclosures would only provide a false veneer of protections that payday lenders would use to bolster their opposition to meaningful consumer protections against unaffordable loans.

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Letters to Regulators: Comment Letter to the CFPB on the Equal Credit Opportunity Act

AFREF and 47 organizations submitted comments on the CFPB’s RFI on the Equal Credit Opportunity Act (ECOA) and Regulation B. Our comments urged the Bureau to take no action that would weaken the ECOA in any way and consider certain steps to improve and strengthen fair lending protections under ECOA to make it stronger and more effective tool for fighting credit discrimination.

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