Joint Letter: 68 Orgs Call on Dept of ED to Preserve Gainful Employment Rule

Americans for Financial Reform Education Fund joined with 67 other organizations working on behalf of students, consumers, vets, servicemembers, civil rights, & college access to urder Education Secretary Betsy Devos not to eliminate the gainful employment rule, which serves to defend students from high-cost, low-return career ed programs. You can find a copy of the letter here.

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Letters to Regulators: AFR sent a letter to the U.S. Commodity Futures Trading Commission criticizing a new de minimis threshold proposal

The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC proposal addresses a wide range of issues surrounding this exemption. These range from the step-down from $8 billion to $3 […]

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Letters to Regulators: AFR commented on Federal Reserve, OCC, FDIC proposed rule regarding the implementation of CECL accounting rules.

Americans for Financial Reform sent a letter to the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation commenting on a proposal to phase-in the regulatory capital effects of implementing the new Current Expected Credit Losses (CECL) accounting methodology. Click here to […]

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Letters to Regulators: AFR commented on a proposal that would cut the minimum required leverage ratio at the largest U.S. banks.

Americans for Financial Reform sent a letter to the Federal Reserve Board of Governors and the Office of the Comptroller of the Currency to comment on a proposal that would reduce the minimum leverage ratio requirements for the largest U.S. banks. Click here to access a PDF version of the letter.  

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Joint Letter: 8 Organizations Warn Regulators Against Bank Payday Loans and Rent-a-Bank Arrangements

“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) […]

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Joint Letter: 8 Organizations Warn Regulators Against Bank Payday Loans and Rent-a-Bank Arrangements

“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”

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Joint Letter to CFPB: An Inquiry Process Weighted in Industry’s Favor

“The RFIs pose questions that are almost entirely from an industry perspective and are insufficiently specific to elicit meaningful comment. The RFIs hint at changes desired by industry without providing enough detail to inform members of the public who do not have experience with the internal workings of the Bureau or the implications of the questions. This process weighted in industry’s favor is not consistent with the CFPB mandate to focus on consumer protection.”

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