Category Archives: Letters to Regulators

Joint Letter: Fed and Treasury Should Freeze M&A Activity as Condition of Aid Money

The Fed must aggressively attempt to retain institutional credibility as a neutral actor in our economic order with regards to the distributional effects of its policies. It should not help finance a merger wave that leads to large-scale consolidation of companies which would have been healthy competitors but for temporary impacts of the current crisis.

Scary Shark in pitch black waters - Photo by Wai Siew on Unsplash

Letter to Regulators: Suspend CFPB Rollback of Payday Loan Protections

[T]he process of rolling back the mandatory underwriting requirement provisions of the 2017 small-dollar lending rule was, at best, highly improper. We urge you to suspend the finalization of the rule pending a full investigation of the facts. There is a strong case to be made that the CFPB needs to restart the regulatory process entirely.

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Letter to Regulators: The Fed must reject any effort by banks to increase involvement in oil and gas

Americans for Financial Reform Education Fund sent a letter to the Federal Reserve Board, urging them to avoid any actions which would permit the financial holding companies or any of their subsidiaries to directly or indirectly operate oil or gas companies. The letter highlights the manifold physical, economic, reputational and financial system risks of bank commodity holdings, risks have become even more severe with the recent dislocation in global energy markets. As these markets will be disrupted for an extended period, the letter asks the Board to firmly reject any effort by banks to use the situation with respect to defaulting loans in the energy industry to increase bank involvement in the oil and gas industry.

Letter to Regulators: End Insider Dominance of Municipal Market Oversight

ACRE, AFSCME, the AFL-CIO, AFR Education Fund, the Consumer Federation of America, and Public Citizen sent a letter to the Municipal Securities Rulemaking Board concerning the need for broader public representation in governance of the Board and oversight of municipal lending markets. The letter is

Comment Letter: Comments on Federal Reserve Emergency Facilities

Together, these facilities could deploy up to $2.3 trillion in new credit to the economy during the pandemic crisis period. Without major changes these facilities will not be effective in getting assistance to those most impacted by the crisis, and disclosure and transparency regarding specific borrowers and loan terms is lacking. Our comment provides specific recommendations to address these issues.