We along with more than 250 organizations separately submitted a letter urging the OCC to refrain from issuing charters to nondepository fintech lenders because doing so would enable the chartered entities to avoid state interest rate caps and other state consumer protection laws, as well as state oversight, thereby putting consumers and small businesses at risk.
“State laws often operate as the primary line of defense for consumers and small businesses; thus, the proposal puts them at great risk. The OCC must not undermine state rate caps. Interest rate caps are the simplest, most effective way to protect borrowers from unaffordable, high-rate loans and to align the interests of lenders and borrowers.”
We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.
We are deeply concerned that the Investment Company Institute (ICI) Letter lays out a set of changes to the Proposed Rule which wold effectively negate the derivatives exposure limits in the rule and render them useless as a tool for controlling speculative leverage at registered funds, as is required by the 1940 Act. …This change would not simply modify the relative weighting of derivatives exposures, but would result in a massive increase in the absolute limit on derivatives risk exposure.
AFR joined with the AFL-CIO in calling on the Securities and Exchange Commission to revise its proposed rule so that “any changes to the Commission’s disclosure rules do not narrow the scope of information that is provided to investors.”
We, the undersigned 724 civil rights, consumer, labor, faith, veterans, seniors, business, and community organizations from all 50 states, write to urge that you ensure the current rulemaking concerning payday, car title, and high‐cost installment loans ends the debt trap. A strong rule must be free of loopholes that will allow predatory practices to continue.
Insurance companies played a significant role in the 2008 financial crisis, both directly and indirectly. American International Group (AIG), the world’s largest insurance group at the time, was at the epicenter of the crisis, and of course collapsed and required the largest government bailout in U.S. history.
“Americans for Financial Reform (“AFR”) appreciates this opportunity to comment on the above referenced proposed rule (the “Rule”) by the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) to restrict the use of forced arbitration clauses in consumer finance contracts. Forced arbitration is a system designed to leave consumers with no practical ability to enforce their most basic rights and protections.”
“The undersigned… organizations strongly support the Consumer Financial Protection Bureau (CFPB)’s proposed rule to limit pre-dispute binding mandatory (or forced) arbitration clauses in consumer finance contracts. The CFPB rule, which will restore consumers’ ability to band together in court to pursue claims, is a significant step forward in the ongoing fight to curb predatory practices in consumer financial products and services and to make these markets fairer and safer. “
Over 18,000 members of Americans for Financial Reform signed a petition calling on the Consumer Financial Protection Bureau to ensure that consumers aren’t deprived of their day in court.