Letters to Regulators: AFR sent a letter to the U.S. Commodity Futures Trading Commission criticizing a new de minimis threshold proposal
AFR Statement: Department of Education’s Proposed New Borrower Defense Rule Sacrifices Students to For-Profit Industry Greed
The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC proposal addresses a wide range of issues surrounding this exemption. These range from the step-down from $8 billion to $3 […]
Congressional Testimony: AFR Policy Director Marcus Stanley testifies to House Financial Services Committee.
“The proposed Borrower Defense rule sacrifices students’ rights in order to line the pockets of executives at for-profit colleges, an industry that has shown time and again that it will use taxpayer dollars to deceive and defraud its own students.” said Alexis Goldstein, AFR’s Senior Policy Analyst. “With this rule and its extreme and absurd barriers to relief, Devos effectively tells students that if a school scams them, they’re on their own.”
Letters to Regulators: AFR commented on Federal Reserve, OCC, FDIC proposed rule regarding the implementation of CECL accounting rules.
On July 17, 2018, AFR Policy Director Marcus Stanley offered testimony at a hearing entitled “Examining Capital Regimes for Financial Institutions,” before the Financial Institutions and Consumer Credit Subcommittee of the House Financial Services Committee.
Letters to Regulators: AFR commented on a proposal that would cut the minimum required leverage ratio at the largest U.S. banks.
Americans for Financial Reform sent a letter to the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation commenting on a proposal to phase-in the regulatory capital effects of implementing the new Current Expected Credit Losses (CECL) accounting methodology. Click here to […]
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
“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.”