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 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.”
The Department of Labor should simply let the fiduciary rule, as written, take full effect. The effort to delay is nothing but an effort to buy time for creating a rationale to roll back the rule, and an abuse of a regulatory process set down in law. Enough.
“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”
Americans for Financial Reform submitted comments to the Department of Education in strong opposition to any delay to or re-opening of the Borrower Defense to Repayment and Gainful Employment regulations. The Department of Education (the “Department”) has already conduced the arduous process of negotiated rulemaking on both of these rules, where all constituencies were able to weigh in. Establishing new negotiated rulemakings on these rules is a waste of taxpayer money and government resources.
The full letter is linked below: Americans for Financial Reform Comment Swaps Entity Capital and Liquidity Requirements
“We welcome the CFPB’s update of Regulation B, which implements the ECOA, and have joined in the comprehensive comments filed by the National Community Reinvestment Coalition. More changes are needed to Regulation B, however, to give consumers stronger protections against discrimination in the credit marketplace.”