“The Proposed Rule is a brazen attempt to dismantle more than 20 years of borrowers’ rights to a defense to repayment on their loans when schools break the law. This dismantling will do nothing more than unleash a new wave of waste, fraud and abuse. This country teaches people that education is a path to a better life. For far too many years, allowing Title IV funds to flow to institutions engaging in fraud has turned this dream into a nightmare for their students. If the Department continues down this path of dismantling the right to a borrower defense, its legacy will be condemning students to lives full of poverty, while allowing executives of predatory proprietary institutions to become wealthy at their expense.”
“In fulfilling its vital mission to protect consumers from deceptive and unfair financial practices, the Bureau needs a Director who is a champion of consumer protection and an advocate for the rights of ordinary Americans against the predations of big banks and unscrupulous market actors. Ms. Kraninger has shown no track record and given no indication in her confirmation hearing or public statements that she would defend the interests of consumers. For that reason we cannot support her nomination.”
The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC proposal addresses a wide range of issues surrounding this exemption. These range from the step-down from $8 billion to $3
The rule’s most significant failing is that it does not establish a clear uniform best interest standard, one that is no less stringent than that found in the Investment Advisers’ Act, for all professionals who provide investment advice to retail clients. Instead, it adopts a weaker standard for broker-dealers that falls short of a true best interest standard and does not adequately address the conflicts of interest that too often are permitted to taint broker-dealers’ recommendations.
On July 24, 2018, Americans for Financial Reform, the Center for Economic Justice, the Consumer Federation of America, and U.S. PIRG, sent a joint letter to members of the House Committee on Financial Services urging them to vote in opposition to HR 5059, the “State Insurance Regulation Preservation Act”. HR 5059 would create a new
Americans for Financial Reform and ten other organizations sent a joint letter to members of the House Committee on Financial Services urging them to reject H.R. 2570, the Mortgage Fairness Act of 2017.
