Category Archives: Letters to Regulators

Letters to Regulators: Letter to FHFA on the Federal Home Loan Bank System

AFREF led 14 organizations in the housing, consumer protection, climate, civil rights, and community investment spaces, in a letter to the Federal Housing Finance Agency regarding the Federal Home Loan Bank system, arguing for expanded contributions to affordable housing to justify the public investment in the system, and for the system to undertake a number of initiatives to support members in reducing their climate risk and climate vulnerability.

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Letter to Regulators: Silicon Valley Bank Failure Demonstrates the Need to Implement Key Executive Pay Rule, Dodd-Frank Section 956

AFREF, the Institute for Policy Studies, Global Economy Project, and Public Citizen led a letter with 22 additional signatories to the agencies tasked with implementing section 956 of Dodd-Frank. That section tasked six agencies with promulgating regulations to prevent incentive-based executive compensation that encourages “inappropriate risk” by May 2011.  Almost 12 years later, we don’t have a final rule. The letter was sent to regulators ahead of congressional hearings that will examine recent bank failures.

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lawyer signing a document Photo by Helloquence on Unsplash

Letters to Regulators: Comment Letter to OMB on Uniform Guidance Relating to Stock Buybacks and Executive Comepensation

AFREF and the Institute for Policy Studies, Global Economy Project led a comment letter to the Office of Management and Budget (OMB) about its uniform guidance, which sets the boundaries around the types of strings states and localities are allowed to attach when they disburse federal funds.  This comment letter argues state and local governments should be allowed to give preferential treatment to bidders that commit to make productive investments in their companies and refrain from stock buybacks and excessive executive compensation.

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Letters to Regulators: Letters to the IRS and Treasury and the CFPB on Medical Debt

 AFREF joined two letters – one to the Internal Revenue Service (IRS) and Department of Treasury, and one to the Consumer Financial Protection Bureau (CFPB) – urging the Biden-Harris Administration to do more to relieve medical debt for tens of millions of people. The letters, signed by more than 60 organizations, include specific executive actions the administration can take to address medical debt.

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Letters to Regulators: Letter to OSTP Raising Concerns about Limits of Blockchain Technology

AFREF and Demand Progress Education Fund submitted comments to the Office of Science and Technology Policy (OSTP) in response to the agency’s request for information regarding the risks, limitations and purported benefits of blockchain technology (including regarding central bank digital currencies), to help inform the government’s research and development agenda on blockchain. The submission raised concerns about the technological limits and risks of blockchain as used for both financial and non-financial applications, as well as a variety of risks, and urged the OSTP to take a more balanced and sober look at blockchain in view of these limitations.

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Letters to Regulators: Letter From 29 Signers to the SEC on Passing Strong Final Rules on Private Fund Advisers to Protect Investors and the Financial System

AFREF led a letter with 29 signers to the Securities and Exchange Commission reiterating the important need to pass a strong set of final rules related to requiring private fund advisers to disclose a complete breakdown of fees/expenses, assumptions used to calculate returns, and the existence of side letters to investors.

The letter is also urging the SEC to finalize a strong set of rules related to requiring private fund advisers over a certain size to report more detailed information about their holdings confidentially to the SEC so that the SEC and other financial regulatory agencies have much greater insight into the risks in the $21 trillion private fund space where there is currently little visibility in order to better safeguard the financial system.

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Letters to Regulators: Letter to ED on IDR Proposed Rulemaking

AFREF joined a letter to the Dept. of Education applauding the Department for the significant positive impact its proposed changes to the IDR rules could have on student loan borrowers.  The proposed rule has the ability to substantially reduce monthly and lifetime payments for millions of borrowers, raise the threshold for protected non-discretionary income, lower the share of discretionary income borrowers have to pay, waive unpaid interest, and decrease time to cancellation.

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