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.
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.
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.
We, the undersigned organizations, call on you to abandon your proposed reorganization of the
Office of Fair Lending and Equal Opportunity, and to remove Mr. Eric Blankenstein from having
any involvement in the Bureau’s oversight and enforcement of antidiscrimination laws. We have
long voiced strong concerns about your plans to relocate the Office of Fair Lending, and our
concerns have grown even stronger in light of the shocking revelations about Mr. Blankenstein’s
writings on issues of race.
Mulvaney chose Blankenstein as the policy associate director for supervision, enforcement, and fair lending. Under Mulvaney the CFPB has restructured the main office for fair lending, expressed interest in moving away from a key legal test for fair lending, and curbed enforcement of rules on predatory lenders that often target communities of color.
Consumer Response has essentially been an independent office housed in the Operations Division. As such, its research on consumer complaint trends has been equally available to all divisions and offices, including, for example, Supervision, Enforcement and Fair Lending; Research, Markets and Regulations; and Consumer Education and Engagement. Is this transfer designed to diminish the Consumer Response unit’s important role in helping all units of the agency collect and understand the ongoing complaints that consumers raise? What benefit does this transfer provide consumers and will this relocation affect the Complaint unit’s budget?
Fair Lending is a fundamentally important part of the work of the Consumer Financial Protection Bureau, and of a financial system that works for families and communities. The Office of Fair Lending and Equal Opportunity needs the authority, the resources, and the connections to key levers of change to do its job.