American Financial Services Association - Legal & Regulatory Affairs
American Financial Services Association

Legal & Regulatory Affairs

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 CommitteeThe 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.

Amicus Briefs

Amicus Brief in Ally Financial v. Haskins

Amicus Brief in Ally Financial v. Haskins

September 20, 2020
Amicus Briefs
Amicus Brief in CDIA v. Frey

Amicus Brief in CDIA v. Frey

April 27, 2020
Amicus Briefs
CDIA v. Frey

CDIA v. Frey

April 27, 2020
Amicus Briefs
Bank of America Corporation Amicus Brief

Bank of America Corporation Amicus Brief

January 23, 2020
Amicus Briefs
Amicus Brief in Rob Miller v. Lobel Financial

Amicus Brief in Rob Miller v. Lobel Financial

April 6, 2019
Amicus Briefs
Amicus Brief in Hanson v. Santander

Amicus Brief in Hanson v. Santander

March 27, 2017
Amicus Briefs
Amicus Brief in Steve Magner v. Thomas J. Gallagher

Amicus Brief in Steve Magner v. Thomas J. Gallagher

December 29, 2011
Amicus Briefs
Amicus Brief in Ryan C. Henry v. Quicken Loans, Inc

Amicus Brief in Ryan C. Henry v. Quicken Loans, Inc

December 12, 2010
Amicus Briefs
Amicus Brief in Weinstat v. Dentsply Inernat., Inc.

Amicus Brief in Weinstat v. Dentsply Inernat., Inc.

February 24, 2010
Amicus Briefs
Amicus Brief in Tillman v. Commercial Credit

Amicus Brief in Tillman v. Commercial Credit

November 21, 2006
Amicus Briefs

Regulatory Comment Letters

AFSA Comments to Treasury Re: CFDI Application

AFSA Comments to Treasury Re: CFDI Application

November 9, 2020
Regulatory Comment Letter
AFSA Comment Letter to FCC re: TCPA Exemptions

AFSA Comment Letter to FCC re: TCPA Exemptions

November 4, 2020
Regulatory Comment Letter
AFSA Letter to CFPB re: RFA Review & Credit Card Market Review

AFSA Letter to CFPB re: RFA Review & Credit Card Market Review

October 28, 2020
Regulatory Comment Letter
Joint Trade Letter re: Remote Notirization

Joint Trade Letter re: Remote Notirization

October 2, 2020
Regulatory Comment Letter
Joint Trade Letter to FCC re: Real-Time Call Blocking Notification

Joint Trade Letter to FCC re: Real-Time Call Blocking Notification

October 1, 2020
Regulatory Comment Letter
Joint Trade Letter to FCC re: Robocall Reduction

Joint Trade Letter to FCC re: Robocall Reduction

September 8, 2020
Regulatory Comment Letter
AFSA Letter to OCC re: National Banks & Federal Savings as Lenders

AFSA Letter to OCC re: National Banks & Federal Savings as Lenders

September 8, 2020
Regulatory Comment Letter
AFSA Letter to CFPB re: Time-Barred Debt

AFSA Letter to CFPB re: Time-Barred Debt

August 4, 2020
Regulatory Comment Letter
AFSA Comment Letter to CFPB re: LIBOR Transition

AFSA Comment Letter to CFPB re: LIBOR Transition

August 4, 2020
Regulatory Comment Letter
AFSA Letter to FTC re: Endorsement Guides

AFSA Letter to FTC re: Endorsement Guides

June 22, 2020
Regulatory Comment Letter
AFSA Comment Letter to FCC re: STIR/SHAKEN

AFSA Comment Letter to FCC re: STIR/SHAKEN

May 15, 2020
Regulatory Comment Letter
Joint Trade Letter to SEC re: Uniform CECL Implementation

Joint Trade Letter to SEC re: Uniform CECL Implementation

March 31, 2020
Regulatory Comment Letter
AFSA Comment Letterto FCC re: Reassigned Numbers Database

AFSA Comment Letterto FCC re: Reassigned Numbers Database

March 12, 2020
Regulatory Comment Letter
AFSA Comments on Call Blocking

AFSA Comments on Call Blocking

February 28, 2020
Regulatory Comment Letter
AFSA letter to FDIC re: permissible interest

AFSA letter to FDIC re: permissible interest

February 4, 2020
Regulatory Comment Letter
AFSA letter to FTC re: accuracy in consumer reporting workshop

AFSA letter to FTC re: accuracy in consumer reporting workshop

February 1, 2020
Regulatory Comment Letter
AFSA letter to OCC re: permissible interest

AFSA letter to OCC re: permissible interest

January 21, 2020
Regulatory Comment Letter
Joint Trade Letter to CFPB re: TRID Assessment

Joint Trade Letter to CFPB re: TRID Assessment

January 21, 2020
Regulatory Comment Letter
Petition for Declaratory Ruling filed by Capital One Services

Petition for Declaratory Ruling filed by Capital One Services

December 23, 2019
Regulatory Comment Letter
AFSA letter to CFPB re: tech sprints

AFSA letter to CFPB re: tech sprints

November 8, 2019
Regulatory Comment Letter
AFSA letter to NHTSA re: E-Titling

AFSA letter to NHTSA re: E-Titling

October 28, 2019
Regulatory Comment Letter
AFSA letter to HUD re: disparate impact rule

AFSA letter to HUD re: disparate impact rule

October 18, 2019
Regulatory Comment Letter
AFSA letter to CFPB re: proposed debt collection rule

AFSA letter to CFPB re: proposed debt collection rule

September 18, 2019
Regulatory Comment Letter
Letter to FCC re: robocalls

Letter to FCC re: robocalls

August 2, 2019
Regulatory Comment Letter
Letter to FTC re: safeguards rule

Letter to FTC re: safeguards rule

August 2, 2019
Regulatory Comment Letter
Letter to FCC re: robocalls

Letter to FCC re: robocalls

July 25, 2019
Regulatory Comment Letter
Letter to FTC re: data privacy

Letter to FTC re: data privacy

June 30, 2019
Regulatory Comment Letter
Letter to FCC Chairman Pai regarding robocalls

Letter to FCC Chairman Pai regarding robocalls

June 18, 2019
Regulatory Comment Letter
Letter to OMB re: CFPB diversity & inclusion form

Letter to OMB re: CFPB diversity & inclusion form

May 23, 2019
Regulatory Comment Letter
Letter to CFPB on proposed payday rule

Letter to CFPB on proposed payday rule

May 15, 2019
Regulatory Comment Letter
AFSA letter to CFPB re: RFI on credit card market

AFSA letter to CFPB re: RFI on credit card market

May 1, 2019
Regulatory Comment Letter
AFSA letter to CFPB re: debt collections survey

AFSA letter to CFPB re: debt collections survey

March 6, 2019
Regulatory Comment Letter
AFSA Letter to FDIC re: industrial bank application process

AFSA Letter to FDIC re: industrial bank application process

February 11, 2019
Regulatory Comment Letter
AFSA Letter to FTC re: identity theft rules

AFSA Letter to FTC re: identity theft rules

February 11, 2019
Regulatory Comment Letter
AFSA Letter to CFPB re: no action letters

AFSA Letter to CFPB re: no action letters

February 11, 2019
Regulatory Comment Letter
AFSA Letter to FDIC re: small-dollar lending rule

AFSA Letter to FDIC re: small-dollar lending rule

January 21, 2019
Regulatory Comment Letter
AFSA Letter to FTC re: military credit monitoring rulemaking

AFSA Letter to FTC re: military credit monitoring rulemaking

January 8, 2019
Regulatory Comment Letter
AFSA Letter to IRS re: proposed regulations under section 199

AFSA Letter to IRS re: proposed regulations under section 199

October 1, 2018
Regulatory Comment Letter
AFSA letter to FTC re: 21st century hearings

AFSA letter to FTC re: 21st century hearings

August 19, 2018
Regulatory Comment Letter
AFSA Letter to HUD re: amendment of fair housing act

AFSA Letter to HUD re: amendment of fair housing act

August 17, 2018
Regulatory Comment Letter
AFSA- RFI on complaint processes

AFSA- RFI on complaint processes

July 16, 2018
Regulatory Comment Letter
AFSA- RFI on financial education

AFSA- RFI on financial education

July 11, 2018
Regulatory Comment Letter
AFSA- RFI on complaint reporting

AFSA- RFI on complaint reporting

July 2, 2018
Regulatory Comment Letter
AFSA- RFI on guidance

AFSA- RFI on guidance

July 2, 2018
Regulatory Comment Letter
AFSA- RFI on inherited rules

AFSA- RFI on inherited rules

June 25, 2018
Regulatory Comment Letter
AFSA- RFI on adopted rules

AFSA- RFI on adopted rules

June 19, 2018
Regulatory Comment Letter
AFSA- RFI on rulemaking process (docket no. cFPB-2018-0009)

AFSA- RFI on rulemaking process (docket no. cFPB-2018-0009)

June 8, 2018
Regulatory Comment Letter
AFSA- RFI external engagements

AFSA- RFI external engagements

May 29, 2018
Regulatory Comment Letter
AFSA letter to CFPB re: RFI on supervision program

AFSA letter to CFPB re: RFI on supervision program

May 21, 2018
Regulatory Comment Letter
AFSA RFI enforcement final [docket no. bureau- 2018-0003]

AFSA RFI enforcement final [docket no. bureau- 2018-0003]

May 14, 2018
Regulatory Comment Letter
Petition for declaratory ruling before the FCC re: TCPA

Petition for declaratory ruling before the FCC re: TCPA

May 5, 2018
Regulatory Comment Letter
AFSA Letter to CFPB re: consumer complaint database

AFSA Letter to CFPB re: consumer complaint database

December 28, 2017
Regulatory Comment Letter
AFSA Letter to CFPB re: RFI on small business lending market

AFSA Letter to CFPB re: RFI on small business lending market

September 14, 2017
Regulatory Comment Letter
AFSA Letter to FCC supporting effort on reassigned numbers

AFSA Letter to FCC supporting effort on reassigned numbers

August 28, 2017
Regulatory Comment Letter
AFSA letter to FCC re: call authentication trust anchor

AFSA letter to FCC re: call authentication trust anchor

August 14, 2017
Regulatory Comment Letter
Letter Supporting FCRA Harmonization Act

Letter Supporting FCRA Harmonization Act

July 11, 2017
Regulatory Comment Letter
Joint coalition letter requesting meeting with attorney general

Joint coalition letter requesting meeting with attorney general

June 30, 2017
Regulatory Comment Letter
Joint trade letter seeks MLA changes from DoD

Joint trade letter seeks MLA changes from DoD

June 23, 2017
Regulatory Comment Letter
Letter supporting declaratory ruling in all about the message

Letter supporting declaratory ruling in all about the message

May 18, 2017
Regulatory Comment Letter
AFSA Letter Supporting Financial CHOICE Act of 2017

AFSA Letter Supporting Financial CHOICE Act of 2017

May 1, 2017
Regulatory Comment Letter
Letter for the Record Supporting CFPB Reform

Letter for the Record Supporting CFPB Reform

March 20, 2017
Regulatory Comment Letter
Joint trade letter re: TCPA express consent

Joint trade letter re: TCPA express consent

March 10, 2017
Regulatory Comment Letter
Coalition Letter to House E&C Supporting HR 985

Coalition Letter to House E&C Supporting HR 985

March 8, 2017
Regulatory Comment Letter
Coalition Letter to House Supporting H.R. 985 FICALA

Coalition Letter to House Supporting H.R. 985 FICALA

March 8, 2017
Regulatory Comment Letter
AFSA letter supporting petition for reconsideration by navient corp.

AFSA letter supporting petition for reconsideration by navient corp.

February 13, 2017
Regulatory Comment Letter
Joint Letter Supporting the Regulatory Accountability Act of 2017

Joint Letter Supporting the Regulatory Accountability Act of 2017

February 6, 2017
Regulatory Comment Letter
AFSA letter commenting on safeguard rules

AFSA letter commenting on safeguard rules

November 21, 2016
Regulatory Comment Letter
AFSA Letter Supporting Financial CHOICE Act of 2016

AFSA Letter Supporting Financial CHOICE Act of 2016

September 12, 2016
Regulatory Comment Letter
AFSA/CBA comment letter on FTC auto survey

AFSA/CBA comment letter on FTC auto survey

March 7, 2016
Regulatory Comment Letter
AFSA Comment letter on "holder rule"

AFSA Comment letter on "holder rule"

February 12, 2016
Regulatory Comment Letter
AFSA Comment letter seeking vendor access to DMDC database

AFSA Comment letter seeking vendor access to DMDC database

February 10, 2016
Regulatory Comment Letter
Joint Trade Letter Seeking Extension of DMDC Registration Deadline

Joint Trade Letter Seeking Extension of DMDC Registration Deadline

January 26, 2016
Regulatory Comment Letter
AFSA letter commenting on CFPB’s arbitration study

AFSA letter commenting on CFPB’s arbitration study

May 21, 2015
Regulatory Comment Letter
AFSA Letter Urging Changes to DoD Military Lending Act Rule

AFSA Letter Urging Changes to DoD Military Lending Act Rule

May 14, 2015
Regulatory Comment Letter
AFSA letter commenting on consumer complaint narrative

AFSA letter commenting on consumer complaint narrative

April 30, 2015
Regulatory Comment Letter
Joint Trade Letter on Finance Product Safety Commission Act

Joint Trade Letter on Finance Product Safety Commission Act

March 4, 2015
Regulatory Comment Letter
Joint Trade Letter to CFPB on Vehicle Finance Study

Joint Trade Letter to CFPB on Vehicle Finance Study

February 18, 2015
Regulatory Comment Letter
AFSA Comment letter on policy on no-action letters

AFSA Comment letter on policy on no-action letters

December 15, 2014
Regulatory Comment Letter
AFSA Comment letter on home mortgage disclosure (regulation c)

AFSA Comment letter on home mortgage disclosure (regulation c)

October 28, 2014
Regulatory Comment Letter
AFSA Comment letter on disclosure of consumer complaint narrative data

AFSA Comment letter on disclosure of consumer complaint narrative data

September 22, 2014
Regulatory Comment Letter
AFSA Comment letter on HMDA.

AFSA Comment letter on HMDA.

May 12, 2014
Regulatory Comment Letter
AFSA Letter to Senators on Traditional Installment Loans

AFSA Letter to Senators on Traditional Installment Loans

March 31, 2014
Regulatory Comment Letter
AFSA Comment letter on debt collection, docket no cFPB-2013-0033

AFSA Comment letter on debt collection, docket no cFPB-2013-0033

February 28, 2014
Regulatory Comment Letter
AFSA Testimony on Soldiers as Consumers

AFSA Testimony on Soldiers as Consumers

November 20, 2013
Regulatory Comment Letter
AFSA Comment Letter to Federal Agencies re: Credit Risk Retention

AFSA Comment Letter to Federal Agencies re: Credit Risk Retention

October 30, 2013
Regulatory Comment Letter
Joint Trade Letter on Privacy Notice Modernization Act

Joint Trade Letter on Privacy Notice Modernization Act

October 29, 2013
Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Company Portal Services Agreement

AFSA Comment Letter to CFPB re: Company Portal Services Agreement

October 16, 2013
Regulatory Comment Letter
Joint Trade Letter Urging Use of QM Standards when Defining QRM

Joint Trade Letter Urging Use of QM Standards when Defining QRM

March 4, 2013
Regulatory Comment Letter
Joint Trade Letter on Mortgage Forgiveness Debt Relief Act

Joint Trade Letter on Mortgage Forgiveness Debt Relief Act

December 12, 2012
Regulatory Comment Letter
AFSA Comment Letter to CFPB re: HOEPA and Finance Charges

AFSA Comment Letter to CFPB re: HOEPA and Finance Charges

September 7, 2012
Regulatory Comment Letter
AFSA Statement to Senate Banking Committee on Military Lending

AFSA Statement to Senate Banking Committee on Military Lending

June 26, 2012
Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Regulation Z

AFSA Comment Letter to CFPB re: Regulation Z

June 8, 2012
Regulatory Comment Letter
Joint Trade letter to CFPB on QM

Joint Trade letter to CFPB on QM

April 16, 2012
Regulatory Comment Letter
Joint Trade Letter on Student Loans and Bankruptcy

Joint Trade Letter on Student Loans and Bankruptcy

March 20, 2012
Regulatory Comment Letter
Joint Trade Letter to CFPB on Privileged Information

Joint Trade Letter to CFPB on Privileged Information

March 7, 2012
Regulatory Comment Letter
AFSA Comment Letter to CFPB re: Credit Card Agreement Prototype

AFSA Comment Letter to CFPB re: Credit Card Agreement Prototype

February 16, 2012
Regulatory Comment Letter
Joint Trade Letter to Congress on Deficit Reduction

Joint Trade Letter to Congress on Deficit Reduction

September 29, 2011
Regulatory Comment Letter
Joint Trade Letter to Congress in Support of Retaining Graves Law

Joint Trade Letter to Congress in Support of Retaining Graves Law

September 7, 2011
Regulatory Comment Letter
AFSA Letter to Federal Agencies Re: Credit Risk Retention

AFSA Letter to Federal Agencies Re: Credit Risk Retention

August 1, 2011
Regulatory Comment Letter
Joint Trade Letter on Housing Finance System

Joint Trade Letter on Housing Finance System

March 29, 2011
Regulatory Comment Letter
AFSA Letter to FTC Re: Motor Vehicle Roundtables

AFSA Letter to FTC Re: Motor Vehicle Roundtables

March 28, 2011
Regulatory Comment Letter
AFSA Comment letter on docket no. 9-1390 (credit protection products)

AFSA Comment letter on docket no. 9-1390 (credit protection products)

December 23, 2010
Regulatory Comment Letter
AFSA Comment letter on exposure draft: leases and exposure draft

AFSA Comment letter on exposure draft: leases and exposure draft

December 8, 2010
Regulatory Comment Letter
AFSA Comment letter on RESPA and TILA disclosures

AFSA Comment letter on RESPA and TILA disclosures

November 10, 2010
Regulatory Comment Letter
AFSA Comment letter on lease accounting project

AFSA Comment letter on lease accounting project

October 21, 2010
Regulatory Comment Letter
AFSA Comment letter on proposed rules of practice and procedure

AFSA Comment letter on proposed rules of practice and procedure

October 12, 2010
Regulatory Comment Letter
AFSA Comment letter on asset-backed securities proposed rule

AFSA Comment letter on asset-backed securities proposed rule

August 2, 2010
Regulatory Comment Letter
Joint Trade Letter Opposing FTC Expansion

Joint Trade Letter Opposing FTC Expansion

June 10, 2010
Regulatory Comment Letter
AFSA Comment letter on docket no. r-1384

AFSA Comment letter on docket no. r-1384

April 14, 2010
Regulatory Comment Letter
AFSA Comment letter on proposed revisions to bankruptcy rule 3001

AFSA Comment letter on proposed revisions to bankruptcy rule 3001

February 16, 2010
Regulatory Comment Letter
AFSA Comment letter on proposed changes to closed-end mortgage rules

AFSA Comment letter on proposed changes to closed-end mortgage rules

December 23, 2009
Regulatory Comment Letter
AFSA Comment letter on regulation z

AFSA Comment letter on regulation z

November 20, 2009
Regulatory Comment Letter
AFSA Comment letter on mortgage acts and practices rulemaking

AFSA Comment letter on mortgage acts and practices rulemaking

July 30, 2009
Regulatory Comment Letter