“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the above mentioned Consultative Document. Among other issues, this Consultative Document proposes to change the measurement of derivatives risk exposures for leverage ratio purposes by replacing the Current Exposure Method (CEM) used today with the Standardized Approach to Counterparty Credit Risk (SA-CCR). The document implies that the SA-CCR has a more realistic approach to risk measurement, while the CEM is more conservative.”

“Americans for Financial Reform (“AFR”) and the Committee for Better Banks (“CBB”) appreciate the opportunity to comment on the Federal Financial Institutions Examination Council (“FFIEC”) notice of proposed revisions to the Uniform Interagency Consumer Compliance Rating System (“CC Rating System”).”

“We are writing in response to the letter you received recently from a number of industry trade groups opposing the inclusion of preferred language data fields in the redesigned Uniform Residential Loan Application (URLA)… The URLA redesign presents a unique and unprecedented opportunity to take an important first step towards addressing equitable access to the mortgage market for LEP consumers and we strongly urge you to include preferred language data fields.”

“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the Federal Reserve Board’s (the “Board”) Notice of Proposed Rulemaking (“Proposed Rule” or “Proposal”) on the above-mentioned rule. Section 165 of the Dodd-Frank Act mandates the imposition of single counterparty credit limits (SCCL), and significantly expands the range of exposures that are captured under such limits. This Proposed Rule is a re-proposal of the Board’s original 2011 proposal regarding credit exposure limits, and makes a number of changes to the original proposal. ”

“Given the complexity of the regulations now applying to global banks, a comprehensive new set of disclosures is absolutely necessary in order to help both investors and civil society organizations such as ourselves understand bank activities. A clear and consistent set of public disclosures should also be helpful for financial regulators, who under the U.S. system do not always have access to bank supervisory data that may be relevant to the markets they oversee.”

Because of the significant harm caused by these robocalls from debt collectors, AFR is very supportive of the consumer protections proposed by the FCC in this rulemaking. The Commission has also proposed two other very important provisions that we think are good, but that need to be improved — including narrowing its limit of three allowable calls per month per loan to three calls per month per servicer.

“…the Consumer Financial Protection Bureau (the “Bureau”) published an interim final rule that redefines the small creditors serving rural and underserved areas who are exempt from certain consumer protections in Regulation Z. The interim final rule dramatically increases the number of lenders who qualify for this exemption. “