AFR commented on the roll back of transparency disclosures to investors in the SEC proposed rule “Investment Company Liquidity Disclosures.”
“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”
“The RFIs pose questions that are almost entirely from an industry perspective and are insufficiently specific to elicit meaningful comment. The RFIs hint at changes desired by industry without providing enough detail to inform members of the public who do not have experience with the internal workings of the Bureau or the implications of the questions. This process weighted in industry’s favor is not consistent with the CFPB mandate to focus on consumer protection.”
Americans for Financial Reform wrote to the Department of Education to voice concerns with two applications they have proposed for higher education institutions seeking access to emergency relief funds. In addition to creating barriers to accessing the funds, the forms are not available in Spanish, which will preclude potential applicants in Puerto Rico from accessing needed funds.
AFR sent a comment letter to the Federal Reserve Board on the proposed new rating system for supervision of large financial institutions.
AFR sent the below letter to the Federal Reserve commenting on a package of proposals for stress test transparency AFR Comment on Stress Test Proposal Package
“On behalf of Americans for Financial Reform, we are writing to express our support for proposed changes…by the Federal Reserve Board of Governors… to the FR Y-15 systemic risk reporting form… regarding the treatment of cleared over-the-counter derivatives transactions.”
AFR sent a comment letter to the Federal Reserve Board urging them to modify proposed rules that would reduce accountability for bank Boards of Directors, and also to examine further changes that would expand such accountability AFR Response to Proposed Guidance On Boards of Directors
“ILC charters exploit a loophole in federal banking laws to gain access to the federal deposit-insurance safety net while avoiding critical federal supervision and regulation. ILCs therefore pose unique risks to the financial system… If these applications are granted, [it] will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications, potentially unleashing a dangerous avalanche of new applications.”