In the wake of market volatility stemming from Archegos Capital, AFR wrote to the Securities and Exchange Commission (SEC), urging action to improve transparency with enhanced 13F disclosures and investigate any regulatory gaps created by the registration exemption for large family offices. You can find a PDF of the letter here, or the full text
AFR joins a letter to the White House and the Council of the Inspectors General on Integrity and Efficiency (CIGIE), calling on President Biden to nominate individuals to fill the fourteen open inspector general positions by June 1, 2021. Inspectors general are a linchpin of government accountability yet fourteen of the seventy-four total offices of the inspectors general are vacant. The ongoing response to COVID-19 has demonstrated the importance of using all available mechanisms within the federal government to ensure proper oversight and accountability of government programs.
AFREF joined our partners in sending a follow-up letter calling on the CFPB to rescind its April 1, 2020 guidance allowing consumer reporting agencies and furnishers to exceed the dispute investigation deadlines under the Fair Credit Reporting Act. In the six months since we sent our last letter, the situation has only gotten worse, with nearly 26,000 more complaints submitted by consumers about delayed or nonexistent responses to credit/consumer reporting disputes. We urged the Bureau to revoke the guidance as soon as possible to prevent further consumer harm.
AFR joined allies across the country to support the Congressional Review Act challenge to the OCC’s final rule, “National Banks and Federal Savings Associations as Lenders,” which would unleash predatory lending in all fifty states by preempting states’ interest rate caps.
AFREF joined a letter opposing the Office of Management and Budget’s proposal to redefine metropolitan statistical areas. The OMB’s proposal would result in a substantial loss for undeserved and under-invested communities by reducing the number of low and moderate income census tracts eligible for Community Reinvestment Act credit and decreasing the number of banks providing Home Mortgage Disclosure Act data, which may pose increased challenges to fair lending enforcement.
AFREF joined our partners to send a letter urging HUD to take further steps to protect FHA borrowers facing COVID-related hardships form foreclosure, including requiring servicers to communicate the availability of several loss mitigation options, providing guidelines for contacting borrowers before the end of a forbearance, and collect performance data on COVID-19 loss mitigation options and make this information available to the public.