On July 23, 2019, AFR Education Fund submitted a letter to the U.S. Securities and Exchange Commission (SEC) opposing a proposal that would create exemptions that would permit U.S. banks – and international banks active in the U.S. market – to do large-scale derivatives dealing in the U.S. without being designated as derivatives dealers under Dodd-Frank Act rules.
The AFR Education Fund sent a statement for the record to the House Financial Services Committee concerning Facebook’s proposal for the Libra digital token and payment system. The statement describes ways in which Facebook is attempting to create an unregulated financial product of potentially global scale and the dangers this would pose to the users of the token and the broader financial system.
AFR wrote a letter to the Federal Reserve Board on a proposal that would liberalize the criteria the Board uses to determine control of a bank. The definition of “control” is critical as it determines whether entities with ownership and influence over banks will be designated as bank holding companies and subject to the appropriate regulation.
Credit reports and credit scores play a critical role in the economic lives of Americans. They are the gatekeeper for affordable credit, insurance, rental housing, and sometimes unfortunately even a job. Yet they suffer from unacceptable rates of inaccuracy. This package would enact a sea change that would make the American credit reporting system more accurate and fairer to consumers.
FHA mortgages play a crucial role in providing and maintaining access to affordable and sustainable homeownership for low- and moderate-income families and communities of color. If the Loan Sale Program continues in its current unregulated form, FHA borrowers and their communities remain at risk of further harm from non-compliant servicers and private equity loan purchasers. It is crucial that HUD implement strong protections both before and after loans are sold to prevent needless borrower displacement and neighborhood instability.
AFR Ed Fund and six other organizations submitted these comments in response to the Department of Housing and Urban Development (HUD)’s advance notice of proposed rulemaking (ANPR) on the FHA Single Family Loan Sale program. View or download pdf of the letter here.