Letters to Regulators: AFR commented on a proposal that would cut the minimum required leverage ratio at the largest U.S. banks.
Letters to Regulators: AFR commented on Federal Reserve proposed changes to capital rules to implement new stress buffer requirements.
Americans for Financial Reform sent a letter to the Federal Reserve Board of Governors and the Office of the Comptroller of the Currency to comment on a proposal that would reduce the minimum leverage ratio requirements for the largest U.S. banks. Click here to access a PDF version of the letter.
Joint Letter: 25 Organizations Write Dept of ED on Evaluating Undue Hardship Claims in Student Loan Bankruptcy
AFR commented on a Federal Reserve proposal that would integrate the capital requirements in its different capital regimes to institute new stress buffer requirements.
Letters to Regulators: AFR opposed roll back of transparency disclosures to investors in SEC proposed rule “Investment Company Liquidity Disclosures.”
AFR was among 25 organizations that signed-on to comments by the National Consumer Law Center on evaluating undue hardship claims in student loan bankruptcy. You can view or download the PDF here.
AFR Statement: Statement on Appointment of Andrew Smith as Head of FTC Bureau of Consumer Protection
AFR commented on the roll back of transparency disclosures to investors in the SEC proposed rule “Investment Company Liquidity Disclosures.”
Joint Letter: 8 Organizations Warn Regulators Against Bank Payday Loans and Rent-a-Bank Arrangements
For its Head of Consumer Protection, the FTC chose a lawyer, Andrew Smith, who worked for both payday lenders and Equifax. The FTC needs a someone with a record of consumer protection, not yet another industry lawyer
AFR Policy Brief: The Toys R’ Us Bankruptcy And Private Equity Predation
“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”
AFR Statement: AFR Criticizes Mulvaney Move to Manipulate Research, Curb Student Advocacy
AFR released the policy brief linked below concerning the role of private equity in the Toys R’ Us bankruptcy and the importance of taking action to limit private equity predation on the businesses they own. The Toys R’ Us Bankruptcy And Private Equity Predation.
AFR Statement: Closing the CFPB’s Office for Students is like shuttering the fire department in the middle of a fire
“What Mulvaney is really interested in is not serious research, but information that advances the interests of the Wall Street banks and predatory lenders he serves.”
Joint Letter to CFPB: An Inquiry Process Weighted in Industry’s Favor
“America is facing an ongoing student debt crisis, with outstanding student debt surpassing $1.5 trillion and over 8 million borrowers in default on their student loans. Closing the Office for Students is like shuttering the fire department in the middle of a three-alarm fire,” said Alexis Goldstein, senior policy analyst at Americans for Financial Reform.
“The RFIs pose questions that are almost entirely from an industry perspective and are insufficiently specific to elicit meaningful comment. The RFIs hint at changes desired by industry without providing enough detail to inform members of the public who do not have experience with the internal workings of the Bureau or the implications of the questions. This process weighted in industry’s favor is not consistent with the CFPB mandate to focus on consumer protection.”