Category Archives: Letters to Regulators

Letter to the Regulators: Emphasizing the Urgent Need to Implement Key Executive Pay Rule, Dodd-Frank Act Section 956

AFREF and Public Citizen led a coalition letter urging the six relevant agencies to implement section 956 of the Dodd-Frank Act, which requires them to promulgate a rule banning incentive-based executive pay that incentivizes inappropriate risk-taking. A year after the 2023 banking crisis — and almost fourteen years after the statutory mandate was enacted — we do not have a rule to protect consumers, depositors, and the public from executives’ excessive risk-taking.

Letters to the Regulators: Letter to the National Association of Insurance Commissioners Outlining the Need for Public, Transparent, and National Data Collection on the Property and Casualty Insurance Market

AFR joined the Consumer Federation of America and 18 other civil rights, housing, and climate advocacy groups in writing this letter to the National Association of Insurance Commissioners regarding the need for a public, transparent, and national data collection on the property and casualty insurance market.

Letters to the Regulators: Letter in Support of Financial Crimes Enforcement Network’s Notice of Proposed Rulemaking to Establish Anti-Money Laundering Regulations for Certain Residential Real Estate Transfers

AFR-EF joined with the FACT Coalition and 35 organizations committed to affordable housing to support the Financial Crimes Enforcement Network (FinCEN) of the United States (U.S.) Department of the Treasury (Treasury)’s notice of proposed rulemaking (NPRM) to establish anti-money laundering regulations for certain residential real estate transfers. Aspiring homebuyers and renters alike simply should not be forced to compete with anonymous entities – including those concealing criminal or other abusive activity – for limited affordable housing options at ever-inflated prices.

Letters to the Regulators: AFR Submits Filing in Opposition to Capital One Financial Corporation’s Acquisition of Discover Financial Services

AFREF wrote a letter in opposition to the proposed Capital One Financial Corporation acquisition of Discover Financial Services, which would substantially erode competition and disadvantage consumers and merchants. The transaction would create the nation’s biggest credit card lender, one of the biggest banks, and a powerful vertically integrated payments network combined with a branch bank and credit card issuer.

Letter to the Regulators: Comment to Treasury FinCEN Supporting Greater Anti-Money Laundering Screening for Registered Investment Advisers, Exempt Reporting Advisers, and Family Offices

Americans for Financial Reform Education Fund wrote a comment supporting the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposals to require additional anti-money laundering and countering of financial terrorism (CFT) requirements for Registered Investment Advisers (RIA). We also encourage FinCEN to jointly propose rulemaking with the Securities and Exchange Commission (SEC) to require the collection of beneficial ownership as well as the creation of a Customer Identification Program (CIP). 

SEC Building

Letter to the Regulators: Letter to the SEC on Finalizing the ESG Funds Disclosures Rule to Protect Investors from Greenwashing and Other Misleading Claims

AFREF and 18 additional signatories wrote to the SEC in support of bringing much-needed disclosures to the vast market of ESG-designated products and services. The letter urges the SEC to finalize the rule titled “Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices” as soon as possible and recommends changes to the way the proposed rule addresses disclosure of metrics by ESG-Focused Funds. These changes would improve the rule by generating disclosures that better reflect ESG-Focused Funds’ varied strategies and priority metrics while alleviating concerns expressed by some commenters.

Letters to the Regulators: Letter Urging End to Overpayments to Insurance Companies and Financial Institutions

AFR joins a sign-on letter urging the Biden Administration to end billions of dollars in overpayments to insurance companies and financial institutions. These wasteful overpayments are causing significant challenges for Medicare’s financial sustainability. The fixes that CMS can and should undertake will help level the playing field between traditional Medicare and Medicare Advantage, promote health equity and bring down Part B premiums for everyone with Medicare.