Americans for Financial Reform submitted comments to the Department of Education in strong opposition to any delay to or re-opening of the Borrower Defense to Repayment and Gainful Employment regulations. The Department of Education (the “Department”) has already conduced the arduous process of negotiated rulemaking on both of these rules, where all constituencies were able to weigh in. Establishing new negotiated rulemakings on these rules is a waste of taxpayer money and government resources.
The full letter is linked below: Americans for Financial Reform Comment Swaps Entity Capital and Liquidity Requirements
“We welcome the CFPB’s update of Regulation B, which implements the ECOA, and have joined in the comprehensive comments filed by the National Community Reinvestment Coalition. More changes are needed to Regulation B, however, to give consumers stronger protections against discrimination in the credit marketplace.”
AFR joined 29 other individuals and organizations representing students, consumers, veterans, servicemembers, and civil rights to send a letter to Education Secretary DeVos raising concerns around the questionable sale of EDMC to the Dream Center Foundation.
“…We urged the Commission to be more aggressive in laying out structural reforms to the markets and more specific limits on dangerous automated trading practices. The current Supplemental NPRM does not change our basic assessment, as it maintains the basic framework of the 2015 NPRM, with no movement toward additional specificity in risk limits or risk control requirements or reduced discretion for market actors in designing and implementing risk controls…
AFR and 30 other organizations sent a sign-on letter to the Consumer Financial Protection Bureau in support of their proposed student loan servicing data collection initiative. Compiling such metrics and borrower outcomes would benefit market participants, federal and state agencies, policymakers, and borrowers. Obtaining a clearer view of the student loan market overall will help inform all market participants on how best to serve student loan borrowers.
“On behalf of Americans for Financial Reform, we are writing to express our support for the Department of Labor’s (DOL’s) conflict of interest rule or “Fiduciary Duty” rule and our strong opposition to eliminating or weakening the rule. This rule strengthens protections for retirement savers by requiring individuals or entities which provide retirement investment advice […]
“We, the undersigned 51 organizations, are writing to express our strong support for the Department of Labor’s (DOL’s) conflict of interest or “Fiduciary Duty” rule and our strong opposition to eliminating or weakening the rule. This rule strengthens protections for retirement savers by requiring financial advisers and their firms to provide retirement investment advice that […]
AFR submitted the comment letter linked and excerpted below that strongly opposes the Department of Labor’s proposal to delay fiduciary protections for retirement investors.
“AFR strongly supports measures to both limit and control risks of physical commodity involvement at financial holding companies. …Specifically, we support the new consolidated limits on the total size of commodity holdings, the capital increase to 300 percent risk weights applied to commodities held under 4(k), and more…”