“On behalf of the undersigned organizations, we urge you to oppose H.R. 1737, the so-called “Reforming CFPB Indirect Auto Financing Guidance Act.” This legislation is simply an effort to stop the CFPB from enforcing laws against discrimination. H.R. 1737 hides its intent behind a smokescreen of claims about process and regulatory jurisdiction. However, the bill is really about the unfair and discriminatory impact of car dealer interest rate markups. “
“On behalf of Americans for Financial Reform, the leading public interest coalition that supported enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) and its members, including the undersigned, we write both to explain the importance of the Act and to demonstrate its constitutionality. While numerous opponents of financial reform have challenged the act’s constitutionality, none have prevailed, in any court.”
“In numerous previous comments, AFR has raised serious concerns about the Commission rules and guidance that exempt foreign subsidiaries of U.S. banks, or U.S. subsidiaries of foreign entities that are highly active on Wall Street, from a wide range of Dodd-Frank derivatives rules. Given the global character of the derivatives market, we believe that such cross-border exemptions create the possibility for large-scale evasion of U.S. rules.”
“AFR supports this proposal to require the recovery of erroneously awarded executive compensation as a condition for exchange listing. Failures in corporate governance have been singled out by many observers, including the Financial Crisis Inquiry Commission, as a significant cause of the global financial crisis. “
“The undersigned consumer and civil rights organizations write to urge you to issue final prepaid card rules that prevent payday lenders and other predatory lenders from attaching dangerous credit features to the cards. We appreciate the strong elements of the proposed rules, which recognize that overdraft services are a form of credit and that credit accessed through cards must have the robust protections of the Credit CARD Act. While the proposed rules will stop some abuses, we are concerned that loopholes in the proposal can be exploited.”
“…responses to the RFI issued by the Department of the Treasury. The extraordinary diversity of on-line lending models and the rapid growth of the sector mean that continued monitoring will be necessary and the sector will likely fall into the purview of multiple regulators. We encourage the Treasury Department to remain active in determining the appropriate regulatory models, and we will further examine the responses to this RFI with interest to evaluate what types of regulation seem appropriate.”
