AFR Weighs in on Defining Larger Market Participants for Student Loan Servicing
AFR joined public interest groups in weighing in on the CFPB’s proposal defining larger market participants for student loan servicing.
Category Archives: Letters to Regulators
AFR Supports Enhanced Regulations for Foreign Banks
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 Letter to CFPB Regarding Affordability in Private Student Loan Market
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.
Fair Housing Letter to Mortgage Settlement Administrator
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
Fair Housing Letter to Mortgage Settlement Monitor
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 Comment Letter Calls for Inclusion of YSP’s in Calculating Points & Fees Thresholds
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.
AFR Letter on Leverage Rules for Swaps Dealers and Broker-Dealers
SEC faulted on proposed capital, margin, and segregation requirements for Security-Based Swap Dealers (“SBSDs”), and capital requirements for Broker Dealers.
AFR Urges Increased Oversight of Money Market Mutual Funds
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.
AFR Calls for Increased Consumer Protections in CFPB’s Trial Disclosures Proposal
AFR submitted a comment letter to the CFPB arguing for the need of rigorous consumer protections attached to any corporate field testing of new disclosure forms.
AFR Letter: Resolution Plans Fall Far Short
More specificity and disclosure are needed in the big banks’ “living wills.”