Letters to Regulators Archives - Page 41 of 54 - Americans for Financial Reform

Letter to Regulators: AFR Comments on the Fed’s Proposed Rule on Credit Limits

“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the Federal Reserve Board’s (the “Board”) Notice of Proposed Rulemaking (“Proposed Rule” or “Proposal”) on the above-mentioned rule. Section 165 of the Dodd-Frank Act mandates the imposition of single counterparty credit limits (SCCL), and significantly expands the range of exposures that are captured under such limits. This Proposed Rule is a re-proposal of the Board’s original 2011 proposal regarding credit exposure limits, and makes a number of changes to the original proposal. ”

Letter to Regulator: AFR Comments to Basel Committee On Bank Transparency

“Given the complexity of the regulations now applying to global banks, a comprehensive new set of disclosures is absolutely necessary in order to help both investors and civil society organizations such as ourselves understand bank activities. A clear and consistent set of public disclosures should also be helpful for financial regulators, who under the U.S. system do not always have access to bank supervisory data that may be relevant to the markets they oversee.”

Letter to Regulators: AFR, 71 Orgs Submit Comment on proposed student loan “Payback Playbook”

“We commend the agencies for their work in compiling this series of potential borrower communications – the
Student Loan Payback Playbooks. It benefits borrowers, servicers, and the agencies to ensure that
federal student loan borrowers are aware of options that will make their student loan payments
affordable and allow them to remain current on their loans.”

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.

Letter to Regulators: AFR Urges Dept of ED to Add Enforceable Borrower Protections to Servicing Contracts, Public Input to Solicitation Process

AFR wrote to the Department of Education and urged them to ensure their contracts with student loan servicers have strong protections for borrowers.

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.”

Letter to Regulators: AFR Joins Consumer Organizations in Commenting to the CFPB on Rural Creditors Rule

“…the Consumer Financial Protection Bureau (the “Bureau”) published an interim final rule that redefines the small creditors serving rural and underserved areas who are exempt from certain consumer protections in Regulation Z. The interim final rule dramatically increases the number of lenders who qualify for this exemption. “

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.”

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.”

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.”