AFR submitted a comment letter to the CFPB supporting their proposed guidance clarifying the relationship of their servicing rules to stronger state laws. The letter also makes suggestions for improvement.
AFR joined more than 45 organizations in submitting a comment letter to the OCC and the FDIC supporting their proposed guidance on bank payday lending. The letter praises their proposal, and adds some additional steps that we believe would be beneficial to curbing the use of payday loans.
AFR joined public interest groups in weighing in on the CFPB’s proposal defining larger market participants for student loan servicing.
AFR submitted a comment letter supporting the proposed rules by the Board of Governors of the Federal Reserve System that set out enhanced prudential standards for foreign banking organizations and foreign non-bank financial companies.
AFR joined public interest groups in submitting a comment letter to the CFPB, arguing that additional information regarding private student loan servicing and collection is needed to design an effective loan modification program.
March 27, 2013 Joseph A. Smith Office of Mortgage Settlement Oversight 301 Fayetteville St., Suite 1801 Raleigh, NC 27601 Members of the Monitoring Committee Via electronic mail Dear Mr. Smith and Members of the Monitoring Committee: We write to follow up on your interim report
March 27, 2013 Joseph A. Smith Office of Mortgage Settlement Oversight 301 Fayetteville St., Suite 1801 Raleigh, NC 27601 Members of the Monitoring Committee Via electronic mail Dear Mr. Smith and Members of the Monitoring Committee: We write to follow up on your interim report
AFR submitted a comment letter to the CFPB calling for yield spread premiums to be included in the calculation of points-and-fees thresholds. This inclusion is very important to carrying out the Dodd-Frank Act directive that prohibits steering borrowers to more expensive loans.
SEC faulted on proposed capital, margin, and segregation requirements for Security-Based Swap Dealers (“SBSDs”), and capital requirements for Broker Dealers.
AFR submitted a comment letter to the Financial Stability Oversight Council urging an increase of oversight of money market mutual funds to address the systemic risk not fully addressed by current oversight rules.