AFREF joined a comment letter in response to the Education Department’s Notice of Proposed Rulemaking on prison education programs, 90/10 and change of ownership.
AFREF sent a letter to the Treasury Department on how to increase transparency in the U.S. Treasury market.
AFREF sent a roadmap for action to the Federal Reserve.
AFREF joined the National Community Reinvestment Coalition, the National Consumer Law Center (on behalf of its low-income clients) and the Center for Responsible Lending in sending a letter to the FDIC saying that Ford Motor Company should be denied deposit insurance for its proposed new Ford Credit industrial loan company (ILC) charter.
AFREF and CRL led a letter calling for the Federal Reserve and the Office of the Comptroller of the Currency (OCC) to reject a proposed merger between TD Bank and First Horizon Bank.
AFREF sent a letter to the Securities and Exchange Commission supporting its proposal to treat index providers as investment advisers given the many traits of index providers that resemble investment advice.
Such proposals are necessary as index funds have grown to become a multi-trillion dollar industry but one whose decisions to include or exclude issuers from the indices, and which many fund managers must closely follow, remain opaque and feature a number of conflicts-of-interest.