“Americans for Financial Reform (“AFR”) and the Committee for Better Banks (“CBB”) appreciate the opportunity to comment on the Federal Financial Institutions Examination Council (“FFIEC”) notice of proposed revisions to the Uniform Interagency Consumer Compliance Rating System (“CC Rating System”).”
“We are writing in response to the letter you received recently from a number of industry trade groups opposing the inclusion of preferred language data fields in the redesigned Uniform Residential Loan Application (URLA)… The URLA redesign presents a unique and unprecedented opportunity to take an important first step towards addressing equitable access to the mortgage market for LEP consumers and we strongly urge you to include preferred language data fields.”
“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the Federal Reserve Board’s (the “Board”) Notice of Proposed Rulemaking (“Proposed Rule” or “Proposal”) on the above-mentioned rule. Section 165 of the Dodd-Frank Act mandates the imposition of single counterparty credit limits (SCCL), and significantly expands the range of exposures that are captured under such limits. This Proposed Rule is a re-proposal of the Board’s original 2011 proposal regarding credit exposure limits, and makes a number of changes to the original proposal. ”
“Given the complexity of the regulations now applying to global banks, a comprehensive new set of disclosures is absolutely necessary in order to help both investors and civil society organizations such as ourselves understand bank activities. A clear and consistent set of public disclosures should also be helpful for financial regulators, who under the U.S. system do not always have access to bank supervisory data that may be relevant to the markets they oversee.”
“We commend the agencies for their work in compiling this series of potential borrower communications – the
Student Loan Payback Playbooks. It benefits borrowers, servicers, and the agencies to ensure that
federal student loan borrowers are aware of options that will make their student loan payments
affordable and allow them to remain current on their loans.”
Because of the significant harm caused by these robocalls from debt collectors, AFR is very supportive of the consumer protections proposed by the FCC in this rulemaking. The Commission has also proposed two other very important provisions that we think are good, but that need to be improved — including narrowing its limit of three allowable calls per month per loan to three calls per month per servicer.
“Unlawful monitoring fee deductions… have been claimed by the private equity industry on an annual basis for many years… Hundreds of millions, if not billions, of tax revenue is lost each and every year of enforcement delay because of the statute of limitations. We hope and expect the IRS to actively, vigorously, and expeditiously enforce current law with respect to ongoing monitoring fee arrangements.”
AFR wrote to the Department of Education and urged them to ensure their contracts with student loan servicers have strong protections for borrowers.
“Yesterday, 164 organizations that advocate on behalf of consumers, students, civil rights, labor, small business, and more, sent a letter to the Consumer Financial Protection Bureau (CFPB), urging the agency to use its Congressional authority to restrict forced arbitration – the abusive practice in which corporations bury “ripoff clauses” in the fine print of take-it-or-leave-it contracts to block consumers from challenging hidden fees, fraud, and other illegal behavior in court.”
“…the Consumer Financial Protection Bureau (the “Bureau”) published an interim final rule that redefines the small creditors serving rural and underserved areas who are exempt from certain consumer protections in Regulation Z. The interim final rule dramatically increases the number of lenders who qualify for this exemption. “