“Americans for Financial Reform (AFR) is pleased to submit these responses to the RFI issued by the Department of the Treasury. The extraordinary diversity of on-line lending models and the rapid growth of the sector mean that continued monitoring will be necessary and the sector will likely fall into the purview of multiple regulators. We encourage the Treasury Department to remain active in determining the appropriate regulatory models, and we will further examine the responses to this RFI with interest to evaluate what types of regulation seem appropriate.”

“In numerous previous comments, AFR has raised serious concerns about the Commission rules and guidance that exempt foreign subsidiaries of U.S. banks, or U.S. subsidiaries of foreign entities that are highly active on Wall Street, from a wide range of Dodd-Frank derivatives rules. Given the global character of the derivatives market, we believe that such cross-border exemptions create the possibility for large-scale evasion of U.S. rules.”

“AFR supports this proposal to require the recovery of erroneously awarded executive compensation as a condition for exchange listing. Failures in corporate governance have been singled out by many observers, including the Financial Crisis Inquiry Commission, as a significant cause of the global financial crisis. “

“The undersigned consumer and civil rights organizations write to urge you to issue final prepaid card rules that prevent payday lenders and other predatory lenders from attaching dangerous credit features to the cards. We appreciate the strong elements of the proposed rules, which recognize that overdraft services are a form of credit and that credit accessed through cards must have the robust protections of the Credit CARD Act. While the proposed rules will stop some abuses, we are concerned that loopholes in the proposal can be exploited.”

“…responses to the RFI issued by the Department of the Treasury. The extraordinary diversity of on-line lending models and the rapid growth of the sector mean that continued monitoring will be necessary and the sector will likely fall into the purview of multiple regulators. We encourage the Treasury Department to remain active in determining the appropriate regulatory models, and we will further examine the responses to this RFI with interest to evaluate what types of regulation seem appropriate.”

“The undersigned consumer, student, education, and civil rights groups submit this comment in support of student loan servicing reform. Fair and accurate student loan servicing is crucial to protect student loan borrowers’ rights under the law and help them repay their loans successfully. “

“As discussed below, we do believe that this proposal outlines a significant rule change that could potentially reverse the statutory intention of the Dodd-Frank Act to provide a majority of independent members on the Board. We suggest that the Board extend the comment period to allow for more detailed examination of this proposal by members of the public interest community with an interest in municipal finance.”

“On behalf of Americans for Financial Reform, we are writing to urge you to reconsider and reverse the Treasury Department’s 2012 Determination that foreign exchange derivatives be excluded from Dodd-Frank regulations covering other forms of over-the-counter derivatives. “