On July 23, 2019, AFR Education Fund submitted a letter to the U.S. Securities and Exchange Commission (SEC) opposing a proposal that would create exemptions that would permit U.S. banks – and international banks active in the U.S. market – to do large-scale derivatives dealing in the U.S. without being designated as derivatives dealers under Dodd-Frank Act rules.
AFR Ed Fund and six other organizations submitted these comments in response to the Department of Housing and Urban Development (HUD)’s advance notice of proposed rulemaking (ANPR) on the FHA Single Family Loan Sale program. View or download pdf of the letter here.
AFREF and our partners sent a letter to the CFPB urging it not to weaken the current protections in the overdraft rule.
Americans for Financial Reform Education Fund raised concerns over weakening resolution planning requirements intended to prepare large bank holding companies for an orderly resolution in conventional bankruptcy without risk to financial stability and without any reliance on extraordinary public support of the failed bank or its counterparties.
Americans for Financial Reform Education Fund sent a letter to banking regulators opposing a proposal that would make the resolution planning process substantially less stringent than it currently is, and raising concerns over the safety and soundness of individual banks and the effect on U.S. financial stability.
Regulatory agencies purport to “tailor” prudential rules, but they are severely undermining capital and liquidity requirements for foreign banks operating in the U.S.
Letter to HUD asking for delay of ANPR until note sale data is released
Americans for Financial Reform Education Fund, as part of a coalition of civil rights, consumer, and labor groups, submitted an official comment letter to the Consumer Financial Protection Bureau excoriating CFPB Director Kathy Kraninger’s proposal to gut a 2017 rule that was issued to stop payday loan debt traps. The coalition’s comment letter, submitted on the last day of the comment period, is a comprehensive rebuttal to Kraninger’s rationales for rolling back consumer protections on payday loans.
Download the letter here
On May 13, 2019, Americans for Financial Reform Education Fund sent a letter to the Financial Stability Oversight Council warning about the dangers of weakening oversight of nonbank financial firms even if such a firm could impose a threat to financial stability.