Category Archives: Letters to Regulators

students in graduation cap and gowns - Photo by Caleb Woods on Unsplash

Joint Statement: Advocates urge President-elect Joe Biden to provide more student debt relief

We welcome the announcement that President-Elect Biden plans to extend the student loan payment pause. However, we encourage him to take immediate executive action on student debt cancellation. We know President-Elect Biden realizes how important student debt relief is, and how many other battles Congress will have in this critical moment. The surest way to get immediate cancellation is through executive action.

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Letters to Regulators: Joint Letter Opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program

AFR Education Fund signed onto a letter opposing the VA’s Proposed COVID-19 Veterans Assistance Partial Claim Payment Program. The letter stated that the proposal cannot achieve its goal of providing a solution for veteran borrowers’ COVID hardships, and urged the VA to revise the proposal to align with existing programs at FHA, USDA, and the Government Sponsored Enterprises. Specifically, the letter stated that the VA should not require monthly payments, funds should not accrue interest, access to the program should be streamlined, and the program should not have a limited time window for relief.

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dollar bills and coins

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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sunrise over a field of wind turbines

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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a house behind bushes

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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SEC Building

Letter to Transition: SEC Needs Chair Committed to Corporate Accountability, Transparent Public Markets.

We urge you to nominate an SEC Chair who is committed to restoring corporate accountability and rebuilding robust, transparent public markets. Our country needs an SEC that will challenge powerful interests on Wall Street to better promote inclusive economic growth, while also protecting main street investors, pension plan participants, workers, and the communities in which we live.

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