AFREF joined a comment letter that strongly supports the CFPB’s proposed safe harbor of $8 for credit card late fees. The CFPB provided ample evidence that this amount is fair, reasonable, and proportional to the costs incurred by issuers for late payments.
AFREF joined a comment letter to OMB on revising their race and ethnicity data standards.
AFREF submitted a letter with partner organizations expressing a mutual concern about the lack of transparency regarding the ownership and control of nursing facilities that serve Medicare and Medicaid beneficiaries.
Americans for Financial Reform Education Fund (AFREF) submitted two letters in response to the Federal Trade Commission (FTC)’s request for comment on updates to its ‘Green Guides’ for the Use of Environmental Marketing Claims. The Guides were last revised in 2012. AFREF joined a coalition
AFREF joined a letter led by the Open Markets Institute and supported by 50 labor and public interest groups urging the Federal Trade Commission (FTC) to ban non-compete clauses as well as functionally equivalent restraints such as training repayment agreement provisions (or TRAPs), for all workers.
AFREF joined partner organizations to comment on the FHA’s 203(k) Rehabilitation Mortgage Insurance Program, a program that provides critical financing for low- and moderate-income people seeking to purchase a home in need of repairs. The comment letter details a number of changes that would increase participation in the program.
AFREF submitted a comment letter in response to the Environmental Protection Agency’s request for information for the Environmental and Climate Justice Block Grant Program (ECJ Program), which provides funding for financial and technical assistance to carry out environmental and climate justice activities to benefit disadvantaged communities. The letter highlights the need for the ECJ Program to minimize barriers for the most climate-vulnerable applicants, prioritize the needs and perspectives of all underrepresented or historically marginalized community members, and prioritize projects that combat the harmful effects of bluelining by financial service providers.
AFREF led 14 organizations in the housing, consumer protection, climate, civil rights, and community investment spaces, in a letter to the Federal Housing Finance Agency regarding the Federal Home Loan Bank system, arguing for expanded contributions to affordable housing to justify the public investment in the system, and for the system to undertake a number of initiatives to support members in reducing their climate risk and climate vulnerability.
AFREF joined a comment to the CFPB supporting the Bureau’s proposal to require nonbank covered persons that are subject to certain agency and court orders to register those orders with the CFPB. The registry will help the CFPB, law enforcement community, and the public limit the harms from repeat offenders.
AFREF, the Institute for Policy Studies, Global Economy Project, and Public Citizen led a letter with 22 additional signatories to the agencies tasked with implementing section 956 of Dodd-Frank. That section tasked six agencies with promulgating regulations to prevent incentive-based executive compensation that encourages “inappropriate risk” by May 2011. Almost 12 years later, we don’t have a final rule. The letter was sent to regulators ahead of congressional hearings that will examine recent bank failures.