Americans for Financial Reform

Government Category: Comments & Letters to Regulators

Letters to Regulators: Letter to ED on IDR Proposed Rulemaking

AFREF joined a letter to the Dept. of Education applauding the Department for the significant positive impact its proposed changes to the IDR rules could have on student loan borrowers.  The proposed rule has the ability to substantially reduce monthly and lifetime payments for millions of borrowers, raise the threshold for protected non-discretionary income, lower the share of discretionary income borrowers have to pay, waive unpaid interest, and decrease time to cancellation.

Letters to Regulators: SEC Climate Disclosure – New Developments February 2023

We are writing on behalf of Public Citizen, Americans for Financial Reform Education Fund, and Sierra Club to supplement the information provided in previous comments we submitted. The purpose of this letter is to highlight a number of recent developments that further strengthen the rationale for the proposed rule.

As explained in our attached summary of developments related to climate-related financial risk, dramatic changes ushered in by the Inflation Reduction Act, the Russian invasion of Ukraine, and global market trends more generally, are accelerating a rapid transformation in the investment landscape.

Letters to Regulators: Letter to the FTC on Junk Fees

AFREF and partners led a letter to the FTC urging it to use its rulemaking authority to protect American consumers from junk fees and put money back into our pockets. Millions of consumers have expressed outrage at the imposition of service fees for live event tickets, “amenity” or “resort” fees charged by hotels, endless surprise rental car fees, hidden internet and cell phone charges, junk fees in the financial sector, and more. The federal government has taken a holistic approach to this problem, including the White House Competition Council, the Consumer Financial Protection Bureau (CFPB), the Department of Transportation (DOT) and now the FTC. 

Letters to Regulators: Federal Reserve Must Finalize Climate Guidance for Banks with Strong Fair Lending Protections

Americans for Financial Reform Education Fund (AFREF) submitted letters to the Federal Reserve Board on its recent climate guidance for large banks.  A coalition letter signed by 24 organizations urged the Fed to include enhanced safeguards and monitoring around fair lending violations, racial and economic justice, and consumer protections as harmful risk management practices like

Letters to Regulators: Letter to the SEC on Standards for Covered Clearing Agencies for U.S. Treasury Securities and Application of the Broker-Dealer Customer Protection Rule With Respect to U.S. Treasury Securities Fund Advisers

AFREF submitted a comment to the Securities and Exchange Commission (SEC) on December 27th supporting its proposals that would centrally clear the $27 trillion U.S. Treasury market, one of the largest and most systemically important markets in the world.  Shockingly, despite the Treasury market’s importance, no one regulator has complete visibility into this market and