Category Archives: Letters to Regulators

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Letter to Regulators: AFR Calls on CFTC to Forcefully Regulate High-speed Automated Trading

“…We urged the Commission to be more aggressive in laying out structural reforms to the markets and more specific limits on dangerous automated trading practices. The current Supplemental NPRM does not change our basic assessment, as it maintains the basic framework of the 2015 NPRM, with no movement toward additional specificity in risk limits or risk control requirements or reduced discretion for market actors in designing and implementing risk controls…

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Letter to the Regulators: AFR, 31 Orgs Support the CFPB’s Student Loan Servicer Data Collection

AFR and 30 other organizations sent a sign-on letter to the Consumer Financial Protection Bureau in support of their proposed student loan servicing data collection initiative. Compiling such metrics and borrower outcomes would benefit market participants, federal and state agencies, policymakers, and borrowers. Obtaining a clearer view of the student loan market overall will help inform all market participants on how best to serve student loan borrowers.

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Letter to Regulators: 34 Organizations Call For Stronger Protections For Consumers with Limited English Proficiency Against Abusive Debt Collection

This letter addresses the CFPB’s proposal related to increasing access to the Fair Debt Collection Practices Act’s protections for Limited English Proficient (LEP) consumers. …Many of these individuals participate in the consumer credit marketplace, but may have greater difficulty navigating the market, especially when debts go into collection and consumers face the legal implications of unpaid debt.”

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Letters to Regulators: Federal Reserve Commodity Proposal

“AFR strongly supports measures to both limit and control risks of physical commodity involvement at financial holding companies. …Specifically, we support the new consolidated limits on the total size of commodity holdings, the capital increase to 300 percent risk weights applied to commodities held under 4(k), and more…”

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Joint Letter to Regulators: More Than 250 Groups Urge OCC Not to Offer Fintech Charters

“State laws often operate as the primary line of defense for consumers and small businesses; thus, the proposal puts them at great risk. The OCC must not undermine state rate caps. Interest rate caps are the simplest, most effective way to protect borrowers from unaffordable, high-rate loans and to align the interests of lenders and borrowers.”