Americans for Financial Reform

Government Category: Comments & Letters to Regulators

Letters to Regulators: AFR Education Fund Calls on SEC for Stronger Regulation of Funds in Wake of March 2020 Bailout

The AFR Education Fund sent a letter to the Securities and Exchange Commission responding to a request for comment on regulatory options for money market funds in light of the collapse and bailout of many money market funds during the March 2020 coronavirus financial shock. The letter called for strong new regulatory steps to fix incentives that create financial instability for these products. It also questioned whether additional regulation should be extended to other types of fixed-income investment funds beyond money market funds narrowly defined, as there is evidence that these types of fund arrangements can also contribute to financial instability.

Letter to Regulators: Federal Reserve Must Do Better on Climate Risk

Americans for Financial Reform Education Fund joined 64 groups in writing a letter to Federal Reserve Chair Powell to take bold and timely action on climate change, in line with the US commitment to the Paris Agreement. The letter asks him to use the Fed’s powers to supervise banks and other financial institutions on climate

Letter to Regulators: In the wake of Archegos, the SEC should end 13F loopholes

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

Letter to Regulators: Fill Vacant Inspector General positions

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.

Letters to Regulators: Letter to the CFPB Re: Renewed Request to Rescind Language in April 1, 2020 CFPB Guidance Allowing CRAs and Furnishers to Exceed FCRA Deadlines for Disputes

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. 

Letters to Regulators: Letter to the OMB Opposing Proposed Redefinition of Metropolitan Statistical Areas

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.