Letters to Regulators: Joint Letter Opposing CFPB’s Seasoning Proposal
Letter to CFPB opposing seasoned mortgage proposal
Government Category: Advocacy Documents
Letter to Regulator: Letter to the SEC Cautioning Against Raising Quarterly Investor Reporting Thresholds by Thirty-Five Times
The Americans for Financial Reform Education Fund is strongly urging the SEC against raising the quarterly reporting requirements for institutional investors 35-fold that would take away up to 90% of the existing reporting that is vital to market participants and researchers alike.
Testimony: License to Bank – Examining the Legal Framework Governing Who Can Lend and Process Payments in the Fintech Age
What industry calls “innovation” is often easily mapped to a longstanding financial service and therefore the existing laws should apply. At the same time, certain tools and certain forms of partnerships should have no place in our economy whatsoever. Treating innovation as an unqualified good leads regulators to ignore both considerations of equity and long-term, sustainable innovation. Give the interface between powerful corporations, complex products, and the public, precaution should be the norm, as it is in food and drug regulation.
Letters to Regulators: Joint Letter Asking CFPB to Rescind Guidance Allowing Credit Reporting Agencies to Ignore Statutory Deadlines
AFR joined our partners in calling on the CFPB to rescind its guidance allowing credit reporting agencies and furnishers to disregard statutory deadlines.
Letters to Regulators: Comments on FDIC RFI on standard setting for fintechs
AFREF and Demand Progress submitted comments to the FDIC on setting standards for fintech companies.
Letter to Regulator: FDIC Should Avoid Industry-Led Standard Setting Organization
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.