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.
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.
More specificity and disclosure are needed in the big banks’ “living wills.”
As speculative interest increases, this vital industrial commodity will be withdrawn from the market, and prices for real-economy businesses and consumers will increase.
AFR joins 10 housing groups in asking OCC to downgrade Wells Fargo for its harmful mortgage and loan servicing practices.
OCC is asked to downgrade the bank over its Direct Deposit Advance loan product.
AFR wrote to prudential regulators concerning margin requirements for uncleared swaps, calling for the strengths in the current proposal to be maintained and also for the proposal to be improved in a number of areas.
FHFA’s proposal to charge more in states with consumer protections has elicited letters of strong opposition from housing and consumer advocates, members of Congress, legal and policy experts, Attorneys General, state legislators, and others.