AFR and its member organizations warn against a proposal that would “severely weaken” the independence measures called for by the Dodd-Frank financial reform law. “A Board dominated by employees of major banks and dealers with subsidiaries active in the municipal market will not be a truly independent Board.”
14 consumer organizations submitted a joint letter to the FTC supporting a proposal to ban telemarketers from using remotely created checks and remotely created payment orders, payment systems commonly used by scammers. The letter also called on the FTC to extend the proposed ban to cover all consumer transactions, not just those conducted via phone.
Joint letter asks the Department of Defense to protect service members from high-cost installment loans and other forms of credit not yet covered by a 36 percent interest-and-fee cap and other protections.
Three years after the Dodd-Frank Act, “There is no excuse for further delay… Without cross-border applicability, there is no effective regulation of derivatives.”
AFR sent a letter to regulators emphasizing the lessons from the Senate Permanent Subcommittee on Investigations (PSI) report on the London Whale.
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.