Americans for Financial Reform Education Fund joined with 61 other organizations to tell the Department of Education that we are closely monitoring their ongoing efforts to recklessly deregulate higher education. As 62 organizations and advocates for students, families, taxpayers, veterans and service members, we wrote to express grave concern that the Department of Education’s 2019 […]
Americans for Financial Reform Education Fund joined with 67 other organizations working on behalf of students, consumers, vets, servicemembers, civil rights, & college access to urder Education Secretary Betsy Devos not to eliminate the gainful employment rule, which serves to defend students from high-cost, low-return career ed programs. You can find a copy of the letter here.
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 […]
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 […]
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.
AFR commented on a Federal Reserve proposal that would integrate the capital requirements in its different capital regimes to institute new stress buffer requirements.
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 commented on the roll back of transparency disclosures to investors in the SEC proposed rule “Investment Company Liquidity Disclosures.”
“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) […]
“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.”