“…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. “
“In this last year of the Obama Administration, this proposed rule deserves priority attention for strengthening a key U.S. defense against money laundering that furthers terrorism, drug trafficking, organized crime, and tax evasion. It would close a major, decade-old gap that has allowed hedge funds, private equity funds, and other big investment firms to accept substantial funds with no questions asked, to facilitate the transfer of offshore funds into the United States without determining their source, and to witness troubling transactions with no legal obligation to report them.”
“… for many years the SEC did not sufficiently address the ways in which Investment Company Act restrictions can be violated through the use of derivatives. The SEC’s basic approach to derivatives risk at funds was set out in a series of releases and no-action letters between 1979 and the late 1980s. The fundamental approach adopted at that time was based on ‘offsetting’ or ‘coverage’ – that is, if a fund segregates assets deemed sufficient to ‘cover’ a derivatives risk, or an offsetting derivatives exposure, then derivatives usage would not violate ’40 Act limitations.”
“On behalf of Americans for Financial Reform, we are writing with regard to your current review of bank safety and soundness rules under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA) Notice #4 (December 23, 2015)… Reviewing these rules before they are finalized and while the process of implementation is still ongoing also carries the risk that the burden of implementation will be mistaken for the permanent effects of the rule.”
“Allowing mortgage applicants to choose in which language they are most comfortable in communicating addresses a major problem of lenders and servicers working with limited English proficiency (LEP) populations and collecting this information through the URLA is the most comprehensive way to do so, because every mortgage borrower fills one out.”
“AFR sent a letter to banking regulators today concerning their review of bank resolution plans. The Dodd-Frank Act requires regulators to review these plans to ensure that major banks are no longer ‘too big to fail’ – that they can go through a conventional (Chapter 11) private bankruptcy in an orderly manner, without creating substantial economic disruption. “
“[T]he proposed Reg AT is long overdue. At the same time, however, the self-regulatory approach taken here falls far short of a clear set of limits on the most dangerous and predatory practices made possible by automated trading technology.”
“We are deeply concerned by the slow pace and small number of discharges that have been processed and that many of the Department’s proposals in the current negotiated rulemaking process move in the wrong direction, reducing eligibility for relief, pitting students against schools, and creating unnecessary burdens on students and the Department.”
“As advocates for students, consumers, veterans, faculty and staff, civil rights and college access, we believe the systematic tracking and reporting of student and borrower complaints is essential to providing quality customer service, ensuring college and loan servicer and collector accountability, and preventing waste, fraud, and abuse of taxpayer dollars.”
“Americans for Financial Reform (“AFR”) appreciates this opportunity to comment Public Consultation on Non-Traditional Non-Insurance Activities and Products (the ‘Consultation’) by the International Association of Insurance Supervisors (the “IAIS”). We believe that improvements in insurance company regulation are necessary to address such systemic risks. “