AFR Education Fund was among the 18 organizations that submitted these comments responding to the CFPB’s RFI on data collection on December 27, 2018. You can view or download pdf of the letter here.
AFR Education Fund was among the 18 organizations that submitted these comments responding to the CFPB’s RFI on data collection on December 27, 2018. You can view or download pdf of the letter here.
Click here to download a PDF version of the letter.
The rule, which was years in the making, created vital protections for consumers of payday, car title, and some longer-term loans to ensure that predatory lenders don’t trap customers in unaffordable loans. Underlying the rule is the common-sense principle that lenders should consider whether borrowers have the ability to repay a loan before they risk their financial well-being.
Click here to download a PDF version of the letter.
Americans for Financial Reform wrote to the Department of Education to voice concerns with two applications they have proposed for higher education institutions seeking access to emergency relief funds. In addition to creating barriers to accessing the funds, the forms are not available in Spanish, which will preclude potential applicants in Puerto Rico from accessing needed funds.
AFR sent the below letter to the Federal Reserve commenting on a package of proposals for stress test transparency AFR Comment on Stress Test Proposal Package
AFR sent a comment letter to the Federal Reserve Board urging them to modify proposed rules that would reduce accountability for bank Boards of Directors, and also to examine further changes that would expand such accountability AFR Response to Proposed Guidance On Boards of Directors
“ILC charters exploit a loophole in federal banking laws to gain access to the federal deposit-insurance safety net while avoiding critical federal supervision and regulation. ILCs therefore pose unique risks to the financial system… If these applications are granted, [it] will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications, potentially unleashing a dangerous avalanche of new applications.”
“In 2013, the FDIC and OCC issued guidance aimed at curbing the harms of these debt trap loans. At the same time, the Federal Reserve issued a supervisory statement to the same end… But today, banks are attacking the FDIC and OCC protections that have prevented banks from trapping people in unaffordable payday loans.”
We write to ask for the bank’s pledge that it will not begin making payday loans, and that it will oppose the
rollback of the regulatory guidance, which would make it easier for other banks to do so.
“Courts and multiple agencies have found – and Wells Fargo has admitted – that the bank has repeatedly ‘violat[ed] laws or regulations.’ In addition, Wells Fargo’s prudential regulator, the Office of the Comptroller of the Currency (OCC), has found the bank’s violations constitute ‘unsafe or unsound practices.’ By statute, either of these criteria is sufficient grounds for termination of a bank’s deposit insurance.”