Category Archives: Letters to Regulators

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Letters to Regulators: Americans for Financial Reform Education Fund letter opposing the FDIC relaxing the process of resolution planning for Insured Depository Institutions

Americans for Financial Reform Education Fund raised concerns over weakening resolution planning requirements intended to prepare large bank holding companies for an orderly resolution in conventional bankruptcy without risk to financial stability and without any reliance on extraordinary public support of the failed bank or its counterparties.

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Letter to Regulators: Coalition Letter to HUD on Opportunity Zones

The 22 community, housing, civil rights, consumer and other organizations believe that HUD must carefully assess the risks and benefits of the Opportunity Zone investments. The Opportunity Zone program poses substantial risks to lower-income households and households of color that already face rapidly rising housing costs and a declining availability of affordable housing options

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Letter to Regulators: New Jersey Investor Protection Rule Would Fill Regulatory Void

Given the unfortunate demise of the Department of Labor (DOL) Fiduciary Rule and the glaring deficiencies in the Securities and Exchange Commission’s (SEC’s) Regulation Best Interest, we greatly appreciate states such as New Jersey that are willing to step in to fill the regulatory void by providing the protections investors need and expect.

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Letter to Regulators: Comprehensive Comment On CFPB’s Proposal To Repeal Payday Rule

The Proposal—a plainly outcome-driven, 47-page exercise in grasping for straws—has offered no reasonable basis to rescind that Rule. Based on a distorted focus on the Rule’s “dramatic impacts” on lenders’ ability to engage in a predatory practice, rather than on the need to protect consumers, the Proposal claims that the evidence must somehow be “more robust.” If the Rule requires significant changes for payday and vehicle title lenders, it is because the harm to consumers is dramatic. The Bureau’s new approach would ignore its consumer protection mandate and require the agency to hesitate when consumer harm is the most severe.