Category Archives: Letters to Regulators

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Letter to Regulators: AFR Supports Strong Consumer Protections in FCC Robocalls Rule

Because of the significant harm caused by these robocalls from debt collectors, AFR is very supportive of the consumer protections proposed by the FCC in this rulemaking. The Commission has also proposed two other very important provisions that we think are good, but that need to be improved — including narrowing its limit of three allowable calls per month per loan to three calls per month per servicer.

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Joint Letter: AFR, 163 Groups Call for Strong CFPB Action Against Forced Arbitration

“Yesterday, 164 organizations that advocate on behalf of consumers, students, civil rights, labor, small business, and more, sent a letter to the Consumer Financial Protection Bureau (CFPB), urging the agency to use its Congressional authority to restrict forced arbitration – the abusive practice in which corporations bury “ripoff clauses” in the fine print of take-it-or-leave-it contracts to block consumers from challenging hidden fees, fraud, and other illegal behavior in court.”

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Letter to Regulators: AFR, 10 Orgs Urge Treasury, FinCEN to Complete the Anti-Money Laundering Rule for Asset Managers

“In this last year of the Obama Administration, this proposed rule deserves priority attention for strengthening a key U.S. defense against money laundering that furthers terrorism, drug trafficking, organized crime, and tax evasion. It would close a major, decade-old gap that has allowed hedge funds, private equity funds, and other big investment firms to accept substantial funds with no questions asked, to facilitate the transfer of offshore funds into the United States without determining their source, and to witness troubling transactions with no legal obligation to report them.”

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Letter to Regulators: AFR Supports SEC Proposal to Restrict Derivatives Use at Mutual Funds

“… for many years the SEC did not sufficiently address the ways in which Investment Company Act restrictions can be violated through the use of derivatives. The SEC’s basic approach to derivatives risk at funds was set out in a series of releases and no-action letters between 1979 and the late 1980s. The fundamental approach adopted at that time was based on ‘offsetting’ or ‘coverage’ – that is, if a fund segregates assets deemed sufficient to ‘cover’ a derivatives risk, or an offsetting derivatives exposure, then derivatives usage would not violate ’40 Act limitations.”

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Letter to Regulators: Regulators Must Not Weaken Dodd-Frank Regulations in the Regulatory Review Process

“On behalf of Americans for Financial Reform, we are writing with regard to your current review of bank safety and soundness rules under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA) Notice #4 (December 23, 2015)… Reviewing these rules before they are finalized and while the process of implementation is still ongoing also carries the risk that the burden of implementation will be mistaken for the permanent effects of the rule.”

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Letter to Regulators: Doing Better by Mortgage Applicants Who Are Not Fluent in English

“Allowing mortgage applicants to choose in which language they are most comfortable in communicating addresses a major problem of lenders and servicers working with limited English proficiency (LEP) populations and collecting this information through the URLA is the most comprehensive way to do so, because every mortgage borrower fills one out.”