As the Federal Deposit Insurance Corporation (FDIC) reassesses third-party partnerships regarding financial technology (fintech), we urge it to refrain from delegating its responsibilities to a public-private standard-setting organization (SSO) and instead to develop its own expertise in the context of a robust, precautionary, approach to oversight. Facilitating compliance with SSO standards is not an acceptable means of regulation, nor an acceptable alternative to regulation.
AFR and our national partners submitted detailed comments opposing the OCC’s proposed true lender rule.
Letter from 101 groups opposing OCC’s true lender rule
The AFR Education Fund wrote a letter to the Commodity Futures Trading Commission regarding its proposed new “Electronic Trading Risk Principles”. The letter faulted the principles-based approach as basically allowing Wall Street to regulate itself in this important area. A copy of the letter can be found here: AFR Education Fund Comment on Electronic Trading
Letter to CFPB urging focused outreach to LEP mortgage borrowers during COVID-19 and expanding language access in mortgage origination and servicing.
Letter from 92 groups urging Congress to include consumer protections in covid-19 relief.
