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.
Americans for Financial Reform Education Fund, Center for Responsible Lending, National Consumer Law Center, National Fair Housing Alliance, and Student Borrower Protection Center sent a joint letter urging HUD to transition to the Secured Overnight Financing Rate (SOFR) and share its LIBOR transition plan as soon as possible. This transition plan should include providing direction to housing counselors about the process and a targeted outreach plan to provide borrowers and all stakeholders with timely, accurate information so that they know what to expect in the months to come.
For over 45 years, the disparate impact doctrine has allowed people to chip away at policies that have a discriminatory effect even if there is no intent to discriminate. When the need to address systemic racism is so urgent, and the costs of failing to do so are so devastating, HUD has chosen to finalize a rule that effectively dismantles this essential tool for fighting injustice.
It is absolutely critical for the well-being of families, communities and the economy that homes are protected. Congress needs to enact measures to protect homeowners and renters, including the following mortgage protections, which our organizations have been advocating:
“We urge you to include these mortgage provisions in the next COVID-19 relief legislation. They will provide homeowners the temporary relief they need to get back on their feet and successfully rebuild their lives.”
Yesterday, HUD finalized a new AFFH rule that is completely contrary to the intent of the AFFH mandate. Instead of furthering fair housing, the rule effectively eliminates a critical tool for addressing discrimination and segregation in our communities.
AFR Ed Fund and 59 other organizations sent a letter to FHFA, Fannie Mae, and Freddie Mac asking them to provide ways for tenants to be able to determine whether their homes qualify for additional protections as a result of their landlord’s forbearance so that they can plan accordingly and protect themselves from eviction and other consequences.
The following organizations have made this important information available in Spanish, Korean, Chinese, Vietnamese, Bangla and English: AFR Language Access Task Force, Americans for Financial Reform Education Fund, Center for Responsible Lending, Consumer Action, Empire Justice Center, National CAPACD, National Consumer Law Center, National Fair Housing Alliance, and UnidosUS.