The undersigned community, consumer, civil rights, faith and small business organizations write to strongly oppose the OCC’s proposed rule addressing state interest rate limits, which threatens to eviscerate state rate caps around the country and encourage the spread of predatory lending.
On January 9, 2020, 29 organizations sent a letter to the Consumer Financial Protection Bureau regarding the importance of applying Truth in Lending Act protections to PACE loans.
We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.
Letter to the NCUA urging them to prioritize consumer compliance
View or download a PDF version of the full letter.
View or download a PDF version of the letter. Consumer Federation of America AFL-CIO Better Markets Center for American Progress Americans for Financial Reform November 21, 2018 Dear Chairman Clayton: We are writing to express our grave concerns regarding PCAOB staff guidance on Rule 3526(b), Communications with Audit Committees Concerning Independence, which was published earlier