Category Archives: Letters to Regulators

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.

by

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.

by
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. 

by
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.

by
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.

by