26 organizations, led by the Consumer Federation of America urge reconsideration of the DOL policy allowing defined contribution plans to invest in private equity funds. Issues raised to the DOL over its original letter considering allowing such funds into private equity include: It fails to give
AFREF joined a letter to the CFPB calling for greater consumer protections in their final debt collection rules.
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.
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.
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
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.
Americans for Financial Reform Education Fund wrote the Fed to express concerns over the blow-up of the Archegos family fund. This incident reveals both the dangers of excessive leverage at private funds, and the failure of banking regulators, including the Federal Reserve, to properly regulate bank interactions with such funds. To address these issues, the Federal Reserve must investigate its own regulatory failures in this case and publicly disclose the lessons learned from this investigation, and must also work with the Financial Stability Oversight Council to address the risks of excessive leverage at private funds.
AFREF joined a letter to the Department of Labor detailing ways to improve protections for retail investors.
AFREF joined a letter to the CFPB requesting they prohibit credit reporting of rent arrears incurred during the COVID-19 pandemic
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.