In the face of supporting evidence described above, in addition to harming retirement savers, the Department would be exposing itself to significant legal risk to change course and further delay the Rule now.
The full letter is linked below: Americans for Financial Reform Comment Swaps Entity Capital and Liquidity Requirements
“We welcome the CFPB’s update of Regulation B, which implements the ECOA, and have joined in the comprehensive comments filed by the National Community Reinvestment Coalition. More changes are needed to Regulation B, however, to give consumers stronger protections against discrimination in the credit marketplace.”
AFR joined 29 other individuals and organizations representing students, consumers, veterans, servicemembers, and civil rights to send a letter to Education Secretary DeVos raising concerns around the questionable sale of EDMC to the Dream Center Foundation.
“…We urged the Commission to be more aggressive in laying out structural reforms to the markets and more specific limits on dangerous automated trading practices. The current Supplemental NPRM does not change our basic assessment, as it maintains the basic framework of the 2015 NPRM, with no movement toward additional specificity in risk limits or risk control requirements or reduced discretion for market actors in designing and implementing risk controls…
AFR and 30 other organizations sent a sign-on letter to the Consumer Financial Protection Bureau in support of their proposed student loan servicing data collection initiative. Compiling such metrics and borrower outcomes would benefit market participants, federal and state agencies, policymakers, and borrowers. Obtaining a clearer view of the student loan market overall will help inform all market participants on how best to serve student loan borrowers.