Letters to Regulators: Letter from 101 Groups Opposing OCC True Lender Proposed Rule
Letter from 101 groups opposing OCC’s true lender rule
Tag Archives: OCC
Letter to Regulator: OCC Should Adopt Precautionary Approach to Digital Banking Activities
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.
Letters to Congress: Joint Letter in Support of HJ Res 90
AFR joined many national, state and local partners in a letter of support of HJ Res. 90, a disapproval resolution that would overturn the OCC’s Community Reinvestment Act rule that was finalized in May.
In The News: Advocates Condemn Rent-a-Bank Rule that Encourages Predatory High-Cost Loans
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.
News Release: OCC Pursues Weakening of CRA Despite COVID-19 Impacts
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.
Joint Letter: Public Interest Groups Call for Financial Regulation Moratorium
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.
Letter to Regulators: Don’t Weaken Derivatives Risk Controls
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
Joint Letter: OCC Proposal Could Greenlight Predatory Lending Schemes
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.
Letter to Regulators: AFR Ed Fund Opposes Elimination of Derivatives Risk Controls
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.