AFREF submitted a comment to the Federal Reserve on its “Proposed Guidelines for Evaluating Account and Service Requests” urging the Federal Reserve to limit access to its payments systems to well-regulated and well-supervised depository institutions to safeguard rules that protect consumers, ensure the stability of the payments system, and require community reinvestment.
AFREF, NCLC, NFHA and NHLP sent a letter to the CFPB, FRB, FDIC, OCC, NCUA and CSBS asking the agencies to update the April 3, 2020 Joint Statement on Supervisory and Enforcement Practices Regarding the Mortgage Servicing Rules in Response to the COVID-19 Emergency and the CARES Act to restore key supervisory and enforcement tools to incentivize servicers to properly handle applications for loss mitigation assistance and require servicers to send loss mitigation notices to borrowers, which are especially critical as forbearances come to an end in the coming months.
AFR and 68 organizations sent a letter to Congress in support of the Veterans and Consumers Fair Credit Act, which would extend the Military Lending Act’s 36% interest rate cap on consumer loans to all Americans.
AFREF joined a letter to the CFPB calling for greater consumer protections in their final debt collection rules.
AFREF joined our partners in sending a follow-up letter calling on the CFPB to rescind its April 1, 2020 guidance allowing consumer reporting agencies and furnishers to exceed the dispute investigation deadlines under the Fair Credit Reporting Act. In the six months since we sent our last letter, the situation has only gotten worse, with nearly 26,000 more complaints submitted by consumers about delayed or nonexistent responses to credit/consumer reporting disputes. We urged the Bureau to revoke the guidance as soon as possible to prevent further consumer harm.
AFR joined a letter with our partners The National Consumer Law Center, Center for Responsible Lending, Consumer Action, Consumer Federation of America, and USPIRG commenting on the CFPB’s Advanced Notice of Proposed Rulemaking regarding consumer access to financial records. The letter responded to several questions from the CFPB to assist in developing a proposed rule to implement Section 1033 of the Dodd Frank Wall Street Reform and Consumer Protection Act. It called for a rule that would ensure control and protection for consumers accessing their own account data.
We applaud the nomination of Rohit Chopra to lead the CFPB. His commitment to consumer protection, his effectiveness at using the tools of government to serve the public interest, and his willingness to challenge powerful corporate interests when necessary are exactly what the Bureau needs to fulfill its crucial consumer protection mission.
The FDIC’s ILC rule threatens state-level consumer protections, further erodes the traditional separation between banking and commerce, and jeopardizes the safety and soundness of the financial system and the economy as a whole.
AFR released policy recommendations to strengthen consumer financial protections and work towards reversing the damage caused by systemic racism, and products and systems that amplify inequality.
AFREF and Demand Progress submitted comments to the FDIC on setting standards for fintech companies.