Americans for Financial Reform

Government Category: Comments & Letters to Regulators

Letters to the Regulators: Letter to the SEC in Opposition to Private Credit Exchange Traded Fund

The Americans for Financial Reform Education Fund led a letter of 10 signers urging the Securities and Exchange Commission (SEC) to reject an application for a novel exchange traded fund (ETF) that would allow retail investors to invest in the $1.7 trillion private credit market. Several larger institutional investors have already taken losses in the private credit market and the letter warns how the presence of an institutional investment manager still fails to mitigate concerns around valuation, conflicts of interest, and suitability.

Letters to the Regulators: Letter in Support of Urging Rulemaking for Tenant Protections Under the Equal Credit Opportunity Act

AFREF submitted a comment letter supporting the National Consumer Law Center’s petition urging the Consumer Financial Protection Bureau to define residential real estate leases as “credit” and landlords as “creditors” under the Equal Credit Opportunity Act. This petition for rulemaking addresses important components of the ongoing legacy of structural racism in credit and residential housing for

Letters to the Regulators: Letter in Support of Urging Rulemaking for Tenant Protections Under the Equal Credit Opportunity Act

AFREF submitted a comment letter supporting the National Consumer Law Center’s petition urging the Consumer Financial Protection Bureau to define residential real estate leases as “credit” and landlords as “creditors” under the Equal Credit Opportunity Act. This petition for rulemaking addresses important components of the ongoing legacy of structural racism in credit and residential housing for people of color seeking rental leases to shelter their families and build a foundation for economic stability.

Letters to the Regulators: AFREF and Allies Commend FDIC Effort to Regulate Industrial Loan Banks

AFREF, Consumer Federation of America, Prof. Arthur Wilmarth, Jr. and Center for Responsible Lending submitted a comment to the Federal Deposit Insurance Corporation supporting the effort to strengthen the oversight of industrial loan companies (ILCs). The proposed rule would heighten scrutiny of new ILCs or attempts to take over existing ILCs that will more fully consider the unique risks of these banks.