AFR sent a comment letter to the Federal Reserve Board urging them to modify proposed rules that would reduce accountability for bank Boards of Directors, and also to examine further changes that would expand such accountability AFR Response to Proposed Guidance On Boards of Directors
“ILC charters exploit a loophole in federal banking laws to gain access to the federal deposit-insurance safety net while avoiding critical federal supervision and regulation. ILCs therefore pose unique risks to the financial system… If these applications are granted, [it] will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications, potentially unleashing a dangerous avalanche of new applications.”
“In 2013, the FDIC and OCC issued guidance aimed at curbing the harms of these debt trap loans. At the same time, the Federal Reserve issued a supervisory statement to the same end… But today, banks are attacking the FDIC and OCC protections that have prevented banks from trapping people in unaffordable payday loans.”
We write to ask for the bank’s pledge that it will not begin making payday loans, and that it will oppose the
rollback of the regulatory guidance, which would make it easier for other banks to do so.
“Courts and multiple agencies have found – and Wells Fargo has admitted – that the bank has repeatedly ‘violat[ed] laws or regulations.’ In addition, Wells Fargo’s prudential regulator, the Office of the Comptroller of the Currency (OCC), has found the bank’s violations constitute ‘unsafe or unsound practices.’ By statute, either of these criteria is sufficient grounds for termination of a bank’s deposit insurance.”
The Department of Labor should simply let the fiduciary rule, as written, take full effect. The effort to delay is nothing but an effort to buy time for creating a rationale to roll back the rule, and an abuse of a regulatory process set down in law. Enough.
We call on the Bureau: to require reporting on the full breadth of small business lending; to capture important data about loans applied for and made; and to complete the rulemaking and begin collection of these data expeditiously.
“By making the fiduciary duty commitment stronger and more specific, these Proposed Revisions to the Standards For Professional Conduct for Certified Financial Planners will enhance CFP client service and assure the public that CFP professionals will reliably act in the best interests of the investor. We strongly support their inclusion in the final revisions to the Standards, and urge the CFP Board to resist any pressures to weaken them.”
“We support the proposed rule but urge the Board to clarify that the presumption be limited to disputes between banks and recommend the Board require banks to maintain original checks for a specified period of time.”
“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.”
“As dominant actors in the mortgage industry with a statutory duty to facilitate underserved communities’ access to homeownership, we welcome the FHFA, Freddie Mac, and Fannie Mae’s consideration of steps to expand access to the mortgage market.”