Contrary to the mission of CRA, the FDIC/OCC proposal makes it easier for banks to ignore the variety of credit needs in the communities they serve, and leave them further behind.
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.
Americans for Financial Reform wrote to Congress to express our support for The Student Borrower Protection Act, The Fair Student Loan Debt Collection Practices Act, and The Private Loan Disability Discharge Act. The student loan protections, transparency measures, and servicing reforms included in these bills are urgently needed so that borrowers are treated more fairly, basic standards are clearer, and borrowers facing challenging circumstances have every opportunity to succeed.
Support letter for the Protecting Your Credit Score Act of 2019
Under the rule, a borrower would have to sign a notice authorizing the lender to withdraw from the account after those two consecutive failures. “If I was smart, I would only sign that if there was money in there,” says Linda Jun, a policy counsel with Americans for Financial Reform, a regulatory and consumer protection coalition. “Aside from getting charged more for a negative balance, banks close bank accounts over this stuff, you could lose access to banking entirely.”
AFR joined 65 other organizations to write in support of S.J.Res. 56 and H.J.Res.76 to undo Education Secretary DeVos’ 2019 Borrower Defense to Repayment rule. The DeVos rule gutted the Obama Administration’s 2016 rule that added further protections to students who are entitled to debt cancellation after their schools broke the law. An analysis of the Department’s own calculations estimates that only 3 percent of the loans that result from school misconduct would be cancelled under the new rule. Schools would be held accountable for reimbursing taxpayers for just 1 percent of these loans.
Nobel laureate economist Joseph Stiglitz: “[A] recent study by groups including Americans for Financial Reform found that private-equity bankruptcies in the retail industry alone cost 600,000 jobs. One of those laid off, Giovanna De La Rosa, told of her experiences in this publication. The best outcome would be fewer bankruptcies, but when they happen, the welfare of workers needs to be at the top of the list, not at the bottom.”
AFR held a day-long convening of experts to discuss emerging issues in the SEC regulation of registered investment companies (mutual funds and Exchange Traded Funds that are registered under the 1940 Act).
Letter to the NCUA urging them to prioritize consumer compliance
FDIC Chair Jelena McWilliams “is doing the bidding of loan sharks who have a decades-long history of trying to get around state consumer protection rules,” Americans for Financial Reform spokesperson Carter Dougherty observed. “And now a federal regulator is helping them do it.”