Americans for Financial Reform

Government Category: Comments & Letters to Regulators

Letter to Regulators: AFR Encourages Treasury to Monitor Peer to Peer Lending

“Americans for Financial Reform (AFR) is pleased to submit these responses to the RFI issued by the Department of the Treasury. The extraordinary diversity of on-line lending models and the rapid growth of the sector mean that continued monitoring will be necessary and the sector will likely fall into the purview of multiple regulators. We encourage the Treasury Department to remain active in determining the appropriate regulatory models, and we will further examine the responses to this RFI with interest to evaluate what types of regulation seem appropriate.”

Letter to Regulators: AFR Supports CFTC Proposal to Toughen Cross Border Margin Rules; Urges Broader Reexamination of Cross Border Regulation

“In numerous previous comments, AFR has raised serious concerns about the Commission rules and guidance that exempt foreign subsidiaries of U.S. banks, or U.S. subsidiaries of foreign entities that are highly active on Wall Street, from a wide range of Dodd-Frank derivatives rules. Given the global character of the derivatives market, we believe that such cross-border exemptions create the possibility for large-scale evasion of U.S. rules.”

Letter to Regulators: AFR Joins 31 Organizations in Cautioning Against Potential Loopholes in CFPB’s Prepaid Card Proposal

“The undersigned consumer and civil rights organizations write to urge you to issue final prepaid card rules that prevent payday lenders and other predatory lenders from attaching dangerous credit features to the cards. We appreciate the strong elements of the proposed rules, which recognize that overdraft services are a form of credit and that credit accessed through cards must have the robust protections of the Credit CARD Act. While the proposed rules will stop some abuses, we are concerned that loopholes in the proposal can be exploited.”