Joint Letter: Letter to the OCC, FDIC, and Fed Opposing Proposal to Raise Appraisal Exemption Threshold
Letter to the OCC, FDIC, and Fed opposing proposal to raise the appraisal exemption threshold
Letter to the OCC, FDIC, and Fed opposing proposal to raise the appraisal exemption threshold
AFREF joined a letter to the OCC, FRB, and FDIC opposing the proposed threshold increase.
Several safeguards are critical to ensure that bank loan programs—particularly those designed for financially distressed consumers—promote financial inclusion rather than exacerbate financial exclusion and distress.
Credit cannot make up for a fundamental lack of income or consistent incapacity to meet expenses, particularly for the borrowers with damaged credit for whom high-cost bank products tend to be designed. Irresponsible loan products merely put these consumers in a cycle of debt, exacerbating, not helping their situation.