Americans for Financial Reform Education Fund joined with 67 other organizations working on behalf of students, consumers, vets, servicemembers, civil rights, & college access to urder Education Secretary Betsy Devos not to eliminate the gainful employment rule, which serves to defend students from high-cost, low-return career ed
“The Proposed Rule is a brazen attempt to dismantle more than 20 years of borrowers’ rights to a defense to repayment on their loans when schools break the law. This dismantling will do nothing more than unleash a new wave of waste, fraud and abuse. This country teaches people that education is a path to a better life. For far too many years, allowing Title IV funds to flow to institutions engaging in fraud has turned this dream into a nightmare for their students. If the Department continues down this path of dismantling the right to a borrower defense, its legacy will be condemning students to lives full of poverty, while allowing executives of predatory proprietary institutions to become wealthy at their expense.”
The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC proposal addresses a wide range of issues surrounding this exemption.
The rule’s most significant failing is that it does not establish a clear uniform best interest standard, one that is no less stringent than that found in the Investment Advisers’ Act, for all professionals who provide investment advice to retail clients. Instead, it adopts a weaker standard for broker-dealers that falls short of a true best interest standard and does not adequately address the conflicts of interest that too often are permitted to taint broker-dealers’ recommendations.
Americans for Financial Reform sent a letter to the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation commenting on a proposal to phase-in the regulatory capital effects of implementing the new
Americans for Financial Reform sent a letter to the Federal Reserve Board of Governors and the Office of the Comptroller of the Currency to comment on a proposal that would reduce the minimum leverage ratio requirements for the largest U.S. banks. Click here to access
AFR commented on a Federal Reserve proposal that would integrate the capital requirements in its different capital regimes to institute new stress buffer requirements.
AFR was among 25 organizations that signed-on to comments by the National Consumer Law Center on evaluating undue hardship claims in student loan bankruptcy. You can view or download the PDF here.
AFR commented on the roll back of transparency disclosures to investors in the SEC proposed rule “Investment Company Liquidity Disclosures.”
“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”