The Americans for Financial Reform Education Fund (AFREF) appreciates the opportunity to comment on the above referenced proposed rule (“the Proposal”) by the Securities and Exchange Commission (the “SEC” of the “Commission”) concerning the simplification and streamlining of the most useful information and fees to
Americans for Financial Reform Education Fund signed onto several letters opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.”
Americans for Financial Reform Education Fund signed onto a predatory lending letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it was inconsistent with the agency’s fundamental charges to ensure safety and soundness, consumer protection, fair lending, and the aims of the Community Reinvestment Act. The letter stated that the OCC did not have the authority to make such a proposal, and that it created an unmistakable and absolute conflict by pressuring banks to finance lenders whose models are driven by unaffordable lending.
Americans for Financial Reform Education Fund signed onto a comment letter, organized by Public Citizen, opposing the OCC’s proposed rule “Fair Access to Financial Services” due to climate concerns. The letter urged the OCC to withdraw the proposal on the basis that it required banks to serve every category of high-risk business, with the express goal of increasing bank lending to risky fossil fuel companies and other polluting sectors, and without regard for strategic or reputational risk. The letter stated that the OCC lacked the legal authority to enact this proposed rule, that banks are acting prudently to exit the fossil fuel industry because of growing climate risk to the sector, and that the OCC should instead scrutinize and curb banks’ involvement with high-emission activities.
Americans for Financial Reform Education Fund signed onto a housing letter opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.” The letter urged the OCC to withdraw the proposed rulemaking in its entirety, on the basis that it is a perversion of long-held anti-discrimination principles. The letter stated that the OCC appropriated civil rights language to protect market activities, drafted vague and unintelligible standards, undermined the ability of financial institutions to consider important facets of reputational risk in making investment and underwriting determinations, and provided a negligently inadequate 45-day comment period in the midst of the COVID crisis.
Private equity giant Apollo Global in 2019 lent large sums of money to trucking company YRC Worldwide. After Apollo’s executives reached out to the White House on getting bailouts in the spring, YRC managed, under mysterious circumstances, to be the greatest beneficiary of a special loan program for companies critical to national security.
We applaud Representatives Ayanna Pressley, Ilhan Omar, Alma Adams and House Financial Services Chairwoman Maxine Waters for introducing the House companion to the Schumer/Warren resolution calling for broad-based federal student debt cancellation via executive action. Cancelling substantial student debt will provide both immediate financial relief to millions of Americans, and crucial economic stimulus for everyone during this protracted crisis — boosting GDP and job creation at a time of intense labor shocks and economic contraction.
Americans for Financial Reform Education Fund signs onto two comment letters to the OCC about Oportun’s application for a national bank charter. The letters express several concerns about Oportun’s practices regarding debt collection, lending and Community Reinvestment Act compliance planning. They urge the OCC to condition Oportun’s charter upon substantial improvement of these practices.
It is deeply disappointing that Congress did not act to extend the federal student loan suspension in the COVID relief bill. This increases the urgency for President-Elect Biden to act, both by extending the pause on student loan payments and by cancelling federal student loan debt.
“The conflict of interest is just so completely glaring,” said Marcus Stanley, the policy director of Americans for Financial Reform, a nonpartisan Wall Street watchdog. “Almost all of ICE’s important activities are regulated in very fine detail by the C.F.T.C.”