Category Archives: Letters to Regulators

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Letter to Regulators: AFR Calls on the Dept of ED to Enforce, Not Dismantle, Borrower Defense and Gainful Employment

Americans for Financial Reform submitted comments to the Department of Education in strong opposition to any delay to or re-opening of the Borrower Defense to Repayment and Gainful Employment regulations. The Department of Education (the “Department”) has already conduced the arduous process of negotiated rulemaking on both of these rules, where all constituencies were able to weigh in. Establishing new negotiated rulemakings on these rules is a waste of taxpayer money and government resources.

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Letter to Regulators: AFR Calls on CFTC to Forcefully Regulate High-speed Automated Trading

“…We urged the Commission to be more aggressive in laying out structural reforms to the markets and more specific limits on dangerous automated trading practices. The current Supplemental NPRM does not change our basic assessment, as it maintains the basic framework of the 2015 NPRM, with no movement toward additional specificity in risk limits or risk control requirements or reduced discretion for market actors in designing and implementing risk controls…

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Letter to the Regulators: AFR, 31 Orgs Support the CFPB’s Student Loan Servicer Data Collection

AFR and 30 other organizations sent a sign-on letter to the Consumer Financial Protection Bureau in support of their proposed student loan servicing data collection initiative. Compiling such metrics and borrower outcomes would benefit market participants, federal and state agencies, policymakers, and borrowers. Obtaining a clearer view of the student loan market overall will help inform all market participants on how best to serve student loan borrowers.

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Letters to Regulators: Federal Reserve Commodity Proposal

“AFR strongly supports measures to both limit and control risks of physical commodity involvement at financial holding companies. …Specifically, we support the new consolidated limits on the total size of commodity holdings, the capital increase to 300 percent risk weights applied to commodities held under 4(k), and more…”