AFR sent a comment letter to the Federal Reserve Board on the proposed new rating system for supervision of large financial institutions.
AFR sent a comment letter to the Federal Reserve Board on the proposed new rating system for supervision of large financial institutions.
AFR sent the below letter to the Federal Reserve commenting on a package of proposals for stress test transparency AFR Comment on Stress Test Proposal Package
View or download PDF version.
AFR sent a comment letter to the Federal Reserve Board urging them to modify proposed rules that would reduce accountability for bank Boards of Directors, and also to examine further changes that would expand such accountability AFR Response to Proposed Guidance On Boards of Directors
“ILC charters exploit a loophole in federal banking laws to gain access to the federal deposit-insurance safety net while avoiding critical federal supervision and regulation. ILCs therefore pose unique risks to the financial system… If these applications are granted, [it] will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications, potentially unleashing a dangerous avalanche of new applications.”
“In 2013, the FDIC and OCC issued guidance aimed at curbing the harms of these debt trap loans. At the same time, the Federal Reserve issued a supervisory statement to the same end… But today, banks are attacking the FDIC and OCC protections that have prevented banks from trapping people in unaffordable payday loans.”
We write to ask for the bank’s pledge that it will not begin making payday loans, and that it will oppose the
rollback of the regulatory guidance, which would make it easier for other banks to do so.
“Courts and multiple agencies have found – and Wells Fargo has admitted – that the bank has repeatedly ‘violat[ed] laws or regulations.’ In addition, Wells Fargo’s prudential regulator, the Office of the Comptroller of the Currency (OCC), has found the bank’s violations constitute ‘unsafe or unsound practices.’ By statute, either of these criteria is sufficient grounds for termination of a bank’s deposit insurance.”
The Department of Labor should simply let the fiduciary rule, as written, take full effect. The effort to delay is nothing but an effort to buy time for creating a rationale to roll back the rule, and an abuse of a regulatory process set down in law. Enough.
We call on the Bureau: to require reporting on the full breadth of small business lending; to capture important data about loans applied for and made; and to complete the rulemaking and begin collection of these data expeditiously.
“We support the proposed rule but urge the Board to clarify that the presumption be limited to disputes between banks and recommend the Board require banks to maintain original checks for a specified period of time.”