AFR joined allies across the country to support the Congressional Review Act challenge to the OCC’s final rule, “National Banks and Federal Savings Associations as Lenders,” which would unleash predatory lending in all fifty states by preempting states’ interest rate caps.
AFR Education Fund wrote a letter to banking regulators calling on them to withdraw a proposed rulemaking on the role of supervisory guidance. The letter criticized the new rule as unnecessary and potentially harmful, since it could limit the ability of bank supervisors to take
Americans for Financial Reform Education Fund signed onto several letters opposing the OCC’s Notice of Proposed Rulemaking “Fair Access to Financial Services.”
Americans for Financial Reform Education Fund signed onto a predatory lending 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 was inconsistent with the agency’s fundamental charges to ensure safety and soundness, consumer protection, fair lending, and the aims of the Community Reinvestment Act. The letter stated that the OCC did not have the authority to make such a proposal, and that it created an unmistakable and absolute conflict by pressuring banks to finance lenders whose models are driven by unaffordable lending.
Americans for Financial Reform Education Fund signed onto a comment letter, organized by Public Citizen, opposing the OCC’s proposed rule “Fair Access to Financial Services” due to climate concerns. The letter urged the OCC to withdraw the proposal on the basis that it required banks to serve every category of high-risk business, with the express goal of increasing bank lending to risky fossil fuel companies and other polluting sectors, and without regard for strategic or reputational risk. The letter stated that the OCC lacked the legal authority to enact this proposed rule, that banks are acting prudently to exit the fossil fuel industry because of growing climate risk to the sector, and that the OCC should instead scrutinize and curb banks’ involvement with high-emission activities.
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 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.
AFR released recommendations for “Day One” policy actions by the Biden Administration in the areas of banking regulation, securities and markets regulation, and addressing systemic risk. These are actions that could be taken without a lengthy rulemaking and would make immediate progress toward a fairer
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.
Thank you for your strong commitment to opposing the Office of the Comptroller of the Currency (OCC)’s efforts to help tech companies dodge regulatory oversight, mix commerce and banking activities, and avoid compliance with consumer protection laws.