American Financial Services Association - Legal & Regulatory Affairs

AFSA’s Legal & Regulatory Affairs Department deals with all aspects of the legal environment facing the industry, including legislative issues and regulatory matters. AFSA maintains high-level relationships with regulatory agencies and industry trade groups enabling AFSA staff to provide leadership and expertise to government and consumer advocacy groups (comment letters, amicus briefs, white papers, testimony)

Much of AFSA’s legal and regulatory work is done through the AFSA Law Committee. The Law Committee helps to create and develop AFSA’s judicial, legislative, and regulatory policies and strategies that affect AFSA member companies. Among the benefits of participation in the Law Committee are remaining up-to-date on issues that confront member companies each day, opportunities to network, and the chance to exchange ideas with other in-house counsel in the industry. General counsels or senior attorneys at AFSA Member companies are eligible for membership.

The Law Committee also has six subcommittees: Vehicle Finance, Payment Card, Emerging Issues, Mortgage Lending, Personal Loan and Litigation.

Law Committee members may access their Community page by clicking here.

If you are a finance company member interested in learning more about the Law Committee and subcommittees, contact Celia Winslow, Senior Vice President.

Jump to Regulatory Comment Letters

Amicus Briefs

Amicus Brief in Ally Financial v. Haskins

Amicus Brief inProperty Casualty Insurers Association of America v. Shaun Donovan and United States Department of Housing and Urban Development

June 11, 2014
Amicus Briefs

Amicus Brief in Sanchez v. Valencia Holding co., Inc.

March 18, 2014
Amicus Briefs

Amicus Brief in American Insurance Association and National Association of Mutual Insurance Companies v. United States Department of Housing and Urban Development and Shaun Donovan

March 18, 2014
Amicus Briefs

American Insurance Association and National Association of Mutual Insurance Companies v. United States Department of Housing and Urban Development and Shaun Donovan

March 18, 2014
Amicus Briefs

Amiscus Brief in Dana Venneman and Therodore Collins v. BMW finance Services Na, LLC and Financial Services Vehicle Trust

February 2, 2014
Amicus Briefs

Amicus Brief in Tiffini Harrelson v. Carmax Auto Superstores California, LLC

October 7, 2013
Amicus Briefs

Amicus Brief in Township of Mount Holly, Kathleen Hoffman and Jules Thiessen v. Mt. Holly Gardens Citizens in Action Inc.

September 3, 2013
Amicus Briefs

Amicus Brief in Jane B. McInnes v. LPL Financial LLC & Another

Amicus Brief in George M. Rieber v. GMAC LLC, Ford Motor Credit Company, General Motors Acceptance Corporation, American Suzuki Financial Services Co., LLC, Sovereign Bank, and HSBC Auto Finance

January 14, 2008
Amicus Briefs

Amicus Brief in Tex Star Motors, Inc. v. Regal Finance Company, Ltd, and Regal Finance Company II, Ltd

Regulatory Comment Letters

Advanced methods to target and eliminate unlawful robocalls, second further notice of proposed rulemaking (cg docket no. 17-59)

June 8, 2018
Regulatory Comment Letter

AFSA Testimony Before the House Financial Services Subcommittee on Financial Institutions and Consumer Credit re: Examination of the Federal Financial Regulatory System and Opportunities for Reform

April 6, 2017
Regulatory Comment Letter

Letter Supporting Amendment to CHOICE 2.0 re: APR Calculation Prohibitions

March 29, 2017
Regulatory Comment Letter

Letter for the Record on Committee Hearing: Ending the De Novo Drought: Examining the Application Process for De Novo Financial Institutions

March 20, 2017
Regulatory Comment Letter

AFSA letter responding to CFPB request for information; notice of proposed rule on payday, vehicle title, and certain high-cost installment loans

November 7, 2016
Regulatory Comment Letter

AFSA letter commenting on request for information on payday loans, vehicle title loans, installment loans, and open-end lines of credit

November 7, 2016
Regulatory Comment Letter

Amendments Relating to Disclosure of Records & Information Docket No. Bureau-2016-0039; RIN 3170-AA63

October 24, 2016
Regulatory Comment Letter

AFSA letter commenting on the proposed rule on payday, vehicle title, and certain high-cost installment loans

October 6, 2016
Regulatory Comment Letter

AFSA letter commenting on interpretive rule – military lending act limitations on terms of consumer credit extended to service members and dependents

September 22, 2016
Regulatory Comment Letter

AFSA Letter Supporting Financial CHOICE Act of 2016

September 12, 2016
Regulatory Comment Letter

AFSA letter commenting on mortgage bankers association petition for exemption from the prior express consent requirement for autodialed and prerecorded calls to wirelesss numbers

September 2, 2016
Regulatory Comment Letter

AFSA Letter to the Senate Banking, Housing and Urban Affairs Committee Chairman and Ranking Member in advance of the CFPB's Semi-Annual Report to Congress

April 5, 2016
Regulatory Comment Letter

Joint trade letter on the proposed collection of information relating to the national survey of existing mortgage borrowers (NSEMB)

January 11, 2016
Regulatory Comment Letter

AFSA Comment letter to the office of the executive secretary of the consumer financial protection bureau regarding the consumer complaint database & data normalization

August 31, 2015
Regulatory Comment Letter

Memo of ex parte communication with mortgage servicer working group and the consumer financial protection bureau

July 20, 2015
Regulatory Comment Letter

AFSA Comment letter to the office of the executive secretary of the consumer financial protection bureau regarding the credit card market

June 17, 2015
Regulatory Comment Letter

AFSA letter commenting on CFPB’s process for determining whether to utilize its authority under dodd-frank section 1028(b) to regulate arbitration

April 29, 2015
Regulatory Comment Letter

AFSA Testimony on Regulatory Burdens on Non-Depository Financial Institutions

April 15, 2015
Regulatory Comment Letter

Joint Trade Letter in Support of the Eliminate Privacy Notice Confusion Act

March 23, 2015
Regulatory Comment Letter

AFSA letter commenting on petition for exemption filed by citizens bank concerning prior express consent under the telephone consumer protection act

March 16, 2015
Regulatory Comment Letter

AFSA letter commenting on CFPB’s consumer complaint intake system company portal boarding form information collection system

February 2, 2015
Regulatory Comment Letter

AFSA Comment letter on limitations on terms of consumer credit extended to service members and dependents

December 22, 2014
Regulatory Comment Letter

AFSA Comment letter on policy on no-action letters

December 15, 2014
Regulatory Comment Letter

AFSA Comment letter on defining larger participants of the automobile financing market and defining certain automobile leasing activity as a financial product or service

December 8, 2014
Regulatory Comment Letter

AFSA Comment letter on request for information regarding the use of mobile financial services by consumers and its potential for improving the financial lives of economically vulnerable consumers

September 10, 2014
Regulatory Comment Letter

AFSA Comment letter on petition for financial stability oversight council rulemaking regarding the authority to require supervision and regulation of certain nonbank financial companies

August 19, 2014
Regulatory Comment Letter

AFSA Comment letter on telephone survey exploring awareness of and perceptions regarding dispute resolution provisions in credit card agreements

June 30, 2014
Regulatory Comment Letter

AFSA Letter to FCC re: Professional Association for Customer Engagement’s Petition for Expedited Declaratory Ruling and/or Expedited Rulemaking

December 19, 2013
Regulatory Comment Letter

AFSA and Consumer Mortgage Coalition Joint Trade Letter to GAO re: CFPB’s Complaint Database Lacks Consumer Privacy Protections

September 4, 2013
Regulatory Comment Letter

AFSA Comment Letter to CFPB re: Telephone Survey Exploring Consumer Awareness of and Perceptions Regarding Dispute Resolution Provisions in Credit Card Agreements

August 6, 2013
Regulatory Comment Letter

AFSA Comment Letter to Federal Docket Management System Office re: Limitations on Terms of Consumer Credit Extended to Service Members and Dependents

August 1, 2013
Regulatory Comment Letter

AFSA Comment Letter to FCC re: Petition for Declaratory Ruling filed by YouMail, Inc.

July 19, 2013
Regulatory Comment Letter

AFSA Comment Letter to Board of Governors of the Federal Reserve System re: Section 318 of Dodd-Frank Act

June 14, 2013
Regulatory Comment Letter

Joint Trades Letter to HUD and CFPB re: Request for Guidance and Clarity on Disparate Impact and Dodd-Frank Mortgage Standards

June 4, 2013
Regulatory Comment Letter

AFSA Comment Letter to FHFA re: Lender Placed Insurance, Terms and Conditions

May 28, 2013
Regulatory Comment Letter

AFSA Comment Letter to CFPB Ombudsman re: Timeframe for Comment Letters and Up-to-date Information from CFPB

March 20, 2013
Regulatory Comment Letter

AFSA Letter to CFPB re: Request for Information Regarding Financial Products Marketed to Students Enrolled in Institutions of Higher Education

March 18, 2013
Regulatory Comment Letter

AFSA Letter to FSOC re: Hearing Procedures for Proceedings Under Title I or Title VIII of the Dodd-Frank Wall Street Reform and Consumer Protection Act

July 30, 2012
Regulatory Comment Letter

AFSA Comment Letter to CFPB Re: Disclosure Notice, State Officials Notice, Adjudication Notice, and Investigations Notice

September 26, 2011
Regulatory Comment Letter

AFSA and NAIB Letter to Federal Reserve Board of Governors Re: Definitions of “Predominantly Engaged in Financial Activities” and “Significant” Nonbank Financial Company and Bank Holding Company

March 30, 2011
Regulatory Comment Letter

Joint Trade Letter on Housing Finance System

March 29, 2011
Regulatory Comment Letter

AFSA Letter to FTC Re: Motor Vehicle Roundtables

March 28, 2011
Regulatory Comment Letter

AFSA Letter to Federal Reserve Board of Governors Re: Interim Mortgage Disclosure Improvement Act Rule to Clarify Certain Provisions of the September 2010 Interim Rule

February 28, 2011
Regulatory Comment Letter

AFSA Letter to FSOC Re: Notice of Proposed Rulemaking Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies

February 25, 2011
Regulatory Comment Letter

AFSA Comment letter on advance notice of proposed rulemaking regarding authority to require supervision and regulation of certain nonbank financial companies

November 5, 2010
Regulatory Comment Letter

AFSA Comment letter on information reporting for payments made in settlement of payment card and third party network transactions

January 25, 2010
Regulatory Comment Letter

AFSA Comment letter on paul d. s. edward's petition for an expedited clarification and declaratory ruling concerning the telephone consumer protection act rules

April 2, 2009
Regulatory Comment Letter