AFR joined a letter to the FTC in response to their Notice of Proposed Rulemaking on auto financing.
News Release: In Evaluating TAB Bank, FDIC Should Consider Consumer Harm, Possible Legal Violations, from Predatory Lending
WASHINGTON – Today a coalition of consumer advocates filed comments with the Federal Deposit Insurance Corporation (FDIC), including a petition signed by more than 44,500 people and a letter describing hundreds of consumer complaints, urging the FDIC to consider Transportation Alliance Bank’s (TAB Bank) predatory rent-a-bank lending in assessing the bank’s performance in meeting community needs under the Community Reinvestment Act.
Letters to Regulators: AFREF Comment on CFPB Proposal to Collect Small Business Lending Data to Enforce Fair Lending Laws
AFREF submitted a comment on the CFPB’s proposal to collect small business lending data to enforce fair lending laws.
Letters to Regulators: Letter to Treasury in Response to Request for Comment on Small Dollar Loan Program Application
AFREF, CRL, CFA, and NCLC sent comments to the Department of Treasury in response to their request for comment concerning the Small Dollar Loan (SDL) Program Application.
Letters to Regulators: Letter to FHFA in Response to Request for Comment on Policy Statement on Fair Lending
AFREF joined several other civil rights, consumer advocacy and housing organizations in sending a letter a comment letter to the Federal Housing Finance Agency (“FHFA”) in response to their request for comment on their Policy Statement on Fair Lending (“Policy Statement”). The letter emphasizes that FHFA’s fair lending oversight of Fannie Mae and Freddie Mac must ensure access to mortgage credit on fair terms for all creditworthy borrowers, regardless of their race, gender, national origin, disability, familial status, or other protected characteristics, which is essential to closing the homeownership and wealth gaps created by exclusionary federal housing policies and ongoing discrimination in the housing marketplace.
Letters to Regulators: Letter Urging Financial Regulators to Consider Fair Lending Risks in Use of Artificial Intelligence
AFREF and 22 organizations submitted comments in response to the regulators’ Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning, urging the financial regulators to consider fair lending risks of using artificial intelligence and machine learning and enact safeguards to prevent disproportionate adverse impacts from the use of AI/ML models.
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.
Letters to Regulators: Letter to the OMB Opposing Proposed Redefinition of Metropolitan Statistical Areas
AFREF joined a letter opposing the Office of Management and Budget’s proposal to redefine metropolitan statistical areas. The OMB’s proposal would result in a substantial loss for undeserved and under-invested communities by reducing the number of low and moderate income census tracts eligible for Community Reinvestment Act credit and decreasing the number of banks providing Home Mortgage Disclosure Act data, which may pose increased challenges to fair lending enforcement.
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.
AFREF and 47 organizations submitted comments on the CFPB’s RFI on the Equal Credit Opportunity Act (ECOA) and Regulation B. Our comments urged the Bureau to take no action that would weaken the ECOA in any way and consider certain steps to improve and strengthen fair lending protections under ECOA to make it stronger and more effective tool for fighting credit discrimination.