Letter from 101 groups opposing OCC’s true lender rule
The AFR Ed Fund and allied organizations submitted a comment to banking regulators highlighting concerns that digital banking activities may discriminate by race or otherwise threaten our civil rights.
Letters to Regulators: Letter to OCC Urging Greater Language Access for LEP consumers with Bank Digital Activities
Letter urging OCC to encourage banks to provide greater language access as banks use more technology in banking services.
Consumer advocates slammed the Office of the Comptroller of the Currency (OCC) for its final rule issued today that encourages online non-bank lenders to launder their loans through banks so they can offer high-cost triple-digit loans in states where such loans are illegal. The rules were strongly opposed by a bipartisan group of attorneys general as well as by numerous community, consumer, civil rights, faith and small business organizations, and may face legal challenges.
Before the onset of the COVID-19 pandemic, black homeownership was already at historically low levels nationwide and the racial wealth gap was widening, leaving communities of color with far less wealth and fewer resources for emergencies. COVID-19 has been particularly devastating for African-Americans, low-income families, and immigrants, who are bearing the brunt of the resulting economic fallout as well.
Every federal agency must dedicate all regulatory resources to addressing COVID-19 and the enforcement of rules meant to protect public health, consumers, investors and retirees, and the integrity and stability of the markets. The pursuit of any non-crisis-related rulemaking would be a misallocation of limited resources that distracts needed focus from U.S. public health and welfare, and financial stability.
AFR Education Fund wrote a letter to banking regulators urging them to maintain risk controls for derivatives transactions at large banks Download the letter here. January 23, 2020 RE: Margin and Capital Requirements for Covered Swaps Entities (OCC Docket ID OCC–2019– 0023; Federal Reserve
A coalition of more than 100 organizations yesterday submitted a public comment in opposition to a proposed rule from the Office of the Comptroller of the Currency (OCC) that would make it easier for payday and other high-cost lenders to use banks as a fig leaf to offer predatory loans at interest rates of 100 percent APR or higher that are prohibited under state rate cap laws.
We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.
In The News: Want To Make Payday Loans In States Where It’s Outlawed? Rent A Bank! (Talking Points Memo)
FDIC Chair Jelena McWilliams “is doing the bidding of loan sharks who have a decades-long history of trying to get around state consumer protection rules,” Americans for Financial Reform spokesperson Carter Dougherty observed. “And now a federal regulator is helping them do it.”