Category Archives: Letters to Regulators

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Letter to Regulator: AFR, 8 organizations provide detailed recommendations to FHFA to improve language access in the mortgage industry

“The burden of interpreting financial services jargon and communicating with lenders and servicers should not rest solely on borrowers. . . . Expanding access to language services throughout the mortgage process would begin to equalize a system that currently undermines the ability of LEP borrowers to understand the complexities of their future homeownership prospects and to protect their home after purchasing it.”

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Letter to Regulators: AFR Opposes SoFi’s Deposit Insurance Application

“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”

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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.