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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.”

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Letters to Regulators: Organizations Weigh in on Treasury’s Peer to Peer Lending

“…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.”

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AFR in the News: Is Regulation the Reason Liquidity Is So Unstable? (American Banker)

“Consumer groups are deeply skeptical of the debate, arguing it is just a talking point for the regional and big banks to weaken Dodd-Frank. ‘It’s basically an attempt to put up a sort of fog of complicated technical terms around industry’s desire to reverse pretty basic financial reforms,’ said Marcus Stanley, policy director for public advocacy group Americans for Financial Reform. There’s no academic consensus on any single best way to measure [liquidity] … so you can raise it as this boogeyman in a way that is not really particularly connected to the substantive issues.'”

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AFR Testimony: Expansion of ERISA Fiduciary Duty Protection is “Long Overdue”

“Over the forty years since the existing DOL rule was written, retirement markets have transformed and workers have become overwhelmingly reliant on self-directed savings. Due to the loopholes in the current rule, brokers providing advice on such self-directed savings can easily evade the fiduciary protections that Congress intended to provide to workers saving for their retirement through employment-based plans.”