AFREF joined a letter to FHFA expressing that rather than imposing punitive measures on consumers, FHFA and Enterprises should use their authority and influence over the housing finance market to incentivize PACE lenders and state actors to enhance consumer protections and adopt policies that limit risk to the Enterprises.
The Americans for Financial Reform Education Fund wrote a letter to the Commodity Futures Trading Commission urging them to strengthen a proposed rule that would fatally weaken the implementation of Title VII of Dodd-Frank and its application to CFTC-regulated derivatives markets. In the letter, AFR Education
“PIR LLC will have to generate substantial additional revenue to service the debt which could force PIR LLC to take advantage of its monopoly position to raise prices to unsustainable levels, impose new service charges, reduce technical upkeep that could impair web connectivity or non-profit email traffic, or pursue other business strategies that could undermine the independence of non-profits including suspending or transferring domain names, in effect a censorship-for-profit strategy that has been used by other domain registries and internet companies.”
The AFR Education Fund wrote a letter to the FDIC regarding the analysis of costs and benefits, in which we urged the regulator not to impose a false and excessively narrow framework of “cost-benefit analysis” on their decisions. Download the letter here.
Read or download the full PDF version of the letter. The AFR Education Fund sent a letter to the Securities and Exchange Commission opposing proposed changes to rules concerning proxy voting advisors and resubmission thresholds for shareholder proposals. Taken together, the changes will dramatically reduce
Letter to HUD opposing the set of deregulatory efforts now under way that are withdrawing crucial commonsense oversight from the housing and financial markets, enabling discrimination, and thereby increasing barriers to affordable housing
AFR Ed Fund joined our partners in a letter to the USDA addressing proposed changes to strengthen and improve loss mitigation options for RHS borrowers.
The undersigned community, consumer, civil rights, faith and small business organizations write to strongly oppose the OCC’s proposed rule addressing state interest rate limits, which threatens to eviscerate state rate caps around the country and encourage the spread of predatory lending.
On January 9, 2020, 29 organizations sent a letter to the Consumer Financial Protection Bureau regarding the importance of applying Truth in Lending Act protections to PACE loans.
We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.