The replacement of the CEM by the SA-CCR would significantly reduce leverage capital requirements for bank derivatives positions, which we believe would cut total capital backing derivatives books at large banks.
9 groups oppose the CFPB’s proposed changes to its no-action letter policy and new sandbox proposal
Letter from 80 groups opposing the CFPB’s changes to its no-action letter policy and new sandbox proposal
Letter urging the CFPB to oppose the banking agencies’ proposal to raise the appraisal exemption threshold
Letter to the OCC, FDIC, and Fed opposing proposal to raise the appraisal exemption threshold
AFREF joined a letter to the OCC, FRB, and FDIC opposing the proposed threshold increase.
Several safeguards are critical to ensure that bank loan programs—particularly those designed for financially distressed consumers—promote financial inclusion rather than exacerbate financial exclusion and distress.
Credit cannot make up for a fundamental lack of income or consistent incapacity to meet expenses, particularly for the borrowers with damaged credit for whom high-cost bank products tend to be designed. Irresponsible loan products merely put these consumers in a cycle of debt, exacerbating, not helping their situation.
January 22, 2019 Americans for Financial Reform Education Fund submitted a letter to banking regulators regarding the relaxation of enhanced prudential standards for large banking institutions. Read or download a PDF version of the letter by following this link.