AFR joins our members in urging OCC to update preemption rules
AFR joined consumer organizations in urging the OCC to update its preemption rules to comply with Dodd Frank reduction of sweeping federal preemption of state consumer protection actions.
AFR and Public Citizen submitted a comment letter to the Federal Reserve Board, calling on them to close the loophole in its proposed ban on big bank mergers,
Sixty groups, along with Americans for Financial Reform, sent a letter to Federal Housing Finance Agency Director Mel Watt today regarding the use of principal reduction as a loss mitigation strategy.
AFR submitted a letter to the Fed and the OCC suggesting that leftover funds from the Independent Foreclosure Review (IFR) be spent to help current and Former homeowners who have been hurt in the foreclosure crisis.
AFR offered comments to regulators on what kinds of risk exposures banks should be required to back with their own capital.
AFR submitted a comment letter to the CFTC regarding the importance of collecting data essential to analyzing potential systemic risk.
“We strongly support the Department of Education’s efforts to keep federal funds from being used to support career education companies that routinely fail to deliver on their promises, leaving students with unmanageable debt. We urge you to stand by the thrust of the regulations the Department proposed in March, and to bolster those regulations in several key ways.”
AFR called on the Securities and Exchange Commission to require the release of loan-level data for asset backed securities, which include the ‘toxic assets’ central to the financial crisis. The AFR comment includes a discussion of privacy controls.
“Americans for Financial Reform supports the separation of banking and commerce as a foundational principle, motivated both by considerations of preserving fairness in competition with non-bank firms who do not have access to the prudential safety net, and by considerations of financial safety and soundness.”
AFR submitted a comment to the Consumer Financial Protection Bureau offering some suggestions on how to strengthen their proposed rule on defining “larger participants” in the international money transfer market. This proposed rule, if adopted, would be the fourth in a series of rulemakings to define ‘larger participants’ in various consumer financial product markets. AFR’s recommendations include expanding the criteria CFPB uses to define larger participants, and covering domestic as well as international money transfers under their supervisory purview.