Letters to Regulators: Letter in Response to the CFPB’s Inquiry into Buy Now, Pay Later
AFREF joined a letter to the CFPB in response to their inquiry into Buy Now, Pay Later (BNPL) credit products that are proliferating across market areas.
AFREF joined a letter to the CFPB in response to their inquiry into Buy Now, Pay Later (BNPL) credit products that are proliferating across market areas.
This morning, the Biden administration unveiled its annual budget, which includes a tax on households with wealth over $100 million, a 1% tax on stock buybacks, and a proposal for a three-year freeze on corporate executives selling their shares after a buyback.
WASHINGTON – More than 75 consumer, housing, civil rights, legal services, faith, community, small business, student borrower, and public interest organizations submitted a joint comment letter to the Consumer Financial Protection Bureau (CFPB) concerning Buy Now, Pay Later (BNPL) credit products. The groups are alarmed by the lack of regulation of this credit product, which is exploding in use, and urge the CFPB to view BNPL products as credit cards covered by the Truth in Lending Act (TILA), to start supervision of this market, and to look out for practices that harm consumers.
WASHINGTON, D.C. — The Securities and Exchange Commission (SEC) has issued an important and thoughtful proposal to require mandatory climate financial risk disclosure from public companies. We look forward to commenting on ways that the proposal must be strengthened, in particular with respect to greenhouse gas emissions reporting and corporate climate-related impacts on communities.
AFREF sent a comment to the Securities and Exchange Commission calling for the agency to close long-running loopholes that have enabled certain hedge funds to use swaps and derivatives to avoid disclosing large positions which in turn can lead to coordinated attacks on companies and unnecessary volatility in the underlying prices of certain companies’ stocks. The implosion of family office Archegos Capital is emblematic of such a problem as its use of certain derivatives to build over an over 10% position of a company’s outstanding shares were never revealed until after it was forced to unwind and leading Globally Systemically Important Banks (G-SIBs) to take over $10 billion in losses as a result.
AFREF sent a comment to the Securities and Exchange Commission supporting the agency’s proposal to expand position disclosure requirements (via Form PF) for both hedge funds and private equity funds. Many of the disclosure exemptions were formed when both types of funds were fractions of the size they are today and would give the SEC and by extension, the Financial Stability Oversight Council (FSOC) critical information to prevent the uncertainty and threats to financial stability that we saw with Long Term Capital Management in 1999 as well as the financial crises of 2008 and March 2020.
Today, in a letter to Congress, 17 national advocacy organizations representing consumers, investors, and digital rights concerns called on the House Financial Services Committee to hold a hearing scrutinizing the steps tech giant Google (Alphabet) is taking to enter the cryptocurrency and digital assets markets, and how such moves might negatively impact privacy rights, consumer protections and safeguards against economic concentration. The call echoes concerns raised previously by advocates regarding Facebook’s designs on the financial services sector with the introduction of its now scuttled stablecoin, Libra (renamed Diem).
AFREF sent a letter commenting on the Security and Exchange Commission’s proposed rule to implement Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, relating to executive compensation for financial performance. The letter welcomes the SEC’s implementation of this important provision and makes recommendations to minimize executives’ incentives to focus on short-term shareholder returns at the expense of longer-term investments that contribute to equitable and sustainable economic growth over time.
We, the undersigned organizations, write to you as advocates of transparency in digital asset markets. The cryptocurrency market boom has led to large corporations investing in the field, including Facebook (now Meta), whose problematic “Libra” cryptocurrency proposal was scrutinized in a 2019 hearing held by the Committee, at your direction. Facebook has since abandoned the project in light of the concerns raised at this hearing and due to push back from policymakers, public interest organizations, and financial regulators.
AFREF joined the Save Our Retirement Coalition on a letter calling on the Department of Labor to expeditiously update and strengthen the rules governing retirement investment advice to help protect workers and retirees from harmful conflicts of interest.