Skip to content

2022 Archives: Financial Security and Livable Communities

AARP correspondence to lawmakers and regulators

The following documents related to consumer affairs, financial security, and livable communities issues that benefit people 50-plus are presented in reverse chronological order.


C: On November 28, 2022 AARP provided comments to the U.S. Department of Labor on the notice of rulemaking regarding the standard for determining who is a covered employee and who is an independent contractor under the Fair Labor Standards Act. In the letter, it was noted that the Department’s proposed rule is a sensible return to a multi-factor “totality of the circumstances” analysis of the economic realities test consistent with the Department’s past regulation and prevailing court precedent. (PDF)

C: On November 23, 2022 AARP submitted comments to the Consumer Financial Protection Bureau in response to a request for information regarding Mortgage Refinances and Forbearances. AARP applauded the CFPB for examining these important issues that affect the long-term financial security of millions of older homeowners and their families, and provided answers to select questions under the sections of “Targeted and Streamlined Refinances, “Potential New Products to Facilitate Refinances,” and “Forebearances and Other Loss Mitigation.” (PDF)

C: On November 21, 2022 AARP submitted comments to the Federal Trade Commission concerning a Trade Regulation Rule on Commercial Surveillance and Data Security. Information technology now permeates the economic and social lives of Americans, and the growing reliance on technology platforms to mediate nearly all aspects of the lives of individuals has resulted in fundamental shifts in the control and application of personal information. This personal information has become the foundation for a new surveillance economy, which is largely invisible to consumers as their data is captured and monetized by third parties. Especially troubling is the application of algorithmic decision-making technologies that may be biased against protected groups, including older Americans. (PDF)


C: On October 17, 2022 AARP submitted comments to the North American Securities Administrators Association on the NASSAA Corporation Finance Section’s Proposed Revisions to the existing NASAA Statement of Policy Regarding Real Estate Investment Trusts (REITs). AARP has a keen interest in the Proposal because the primary victim in suitability and fraud cases with these products are older Americans. AARP supports initiatives by securities regulators to modernize the framework for oversight of REITs, and specifically, to elevate protections afforded to retail investors. (PDF)

C: On October 5, 2022 AARP submitted comments to the U.S. Equal Employment Opportunity Commission (EEOC) following a listening session held on September 22, 2022 by the Commission regarding its Strategic Enforcement Plan, where AARP also testified. The purpose for the follow up comments is to make sure that the employment barriers many older workers face are part of the Commission’s priorities for fiscal years 2022-2026. (PDF)


C: On September 30, 2022 AARP submitted comments to U.S. Securities and Exchange Commission Secretary Vanessa Countryman in response to the Securities and Exchange Commission’s request for public comment on its Strategic Plan for FY 2022 through FY 2026. AARP’s comments consisted of various suggested revisions, to include directly referencing older Americans as a priority including retired investors who are no longer working and allocate significant resources to the protection of such older investors and retirees. (PDF)

L: On September 15, 2022 AARP sent a letter to U.S. Senate Majority Leader Charles Schumer and Minority Leader Mitch McConnell urging the Congress to provide the Social Security Administration (SSA) with the funding it needs to fulfill its vital mission in a timely and effective manner. Over the past decade, the SSA has been plagued with serious customer service deficiencies occasioned by underfunding. AARP strongly urges the Congress to provide no less than Acting SSA Commissioner Kilolo Kijakazi’s request for FY 2023, $15.356 billion, including funding for the Office of the Inspector General, research and demonstrations. (PDF)

L: On September 12, 2022 AARP sent a letter to Acting Commissioner Kilolo Kijakazi for the Social Security Administration to express serious concerns regarding customer service. AARP believes that all Americans deserve to receive timely and accurate services from the agency, and to do so in a way that protects their health and safety. (PDF)


L: On August 8, 2022 AARP sent letters to U.S. Senators Bob Casey (D-PA) and Steve Daines (R-MT), and Chairman Bobby Scott and Ranking Member Cathy McMorris Rodgers of the U.S. House Committee on Energy and Commerce endorsing the Transformation to Competitive Integrated Employment Act. This legislation would phase out subminimum wages for people with disabilities and allow them to earn fair compensation. (Senate – PDF) (House – PDF)

C: On August 5th, AARP filed comments with the Federal Reserve, the FDIC, and the Office of the Comptroller, on the joint proposed rule to overhaul the Community Reinvestment Act, a 1977 law designed to encourage commercial banks and savings associations to help meet the needs of borrowers in all segments of their communities, including low- and moderate-income neighborhoods. AARP urged all three regulating entities that oversee implementation of the CRA to give high priority to strong consumer lending and affordable housing options, along with adhering to the agencies’ earlier precedent of conducting joint rulemakings on the CRA. Finally, AARP’s comments urged that the final rule include data on race and ethnicity in the CRA bank ratings exams. (PDF)


S: On July 19, 2022 AARP Louisiana State Director Denise Bottcher testified on behalf of AARP as a witness before the U.S. House Committee on Homeland Security Subcommittee on Emergency Preparedness, Response, and Recovery at a hearing titled, “Supporting Underserved Communities in Emergency Management.” The testimony is centered on the findings of the joint AARP – FEMA Resilience Toolkit which was released on July 13, and on the experiences of AARP state offices in emergency preparedness and response. Other witnesses include representatives from Save the Children, the World Institute on Disability, and the Institute for Diversity and Inclusion in Emergency Management,  and the emergency management division of Marion County, Florida. (PDF)


L: On June 22, 2002 AARP sent a letter to Chair Tammy Baldwin and Ranking Member John Hoeven of the U.S. House Committee on Agriculture, Subcommittee on Agriculture, Rural Development, FDA & Related Agencies requesting the Committee pay special attention to funding for various programs critical to the well-being of millions of older Americans. The letter specifically focuses on the Supplemental Nutrition Assistance Program, the Commodity Supplemental Food Program, and USDA Rural Housing. (PDF)

L: On June 21, 2022 AARP sent a letter to Chair David Price and Ranking Member Mario Diaz-Balart of the U.S. House Committee on Appropriations, Subcommittee on Transportation, Housing and Urban Development & Related Agencies urging the Committee to invest in programs that support senior housing and transportation. The letter specifically focused on Housing for the Elderly, Rental Assistance, Public Housing Preservation, and the Federal Transit Administration. (PDF)

L: On June 21, 2022 AARP sent a letter to Chair Rosa DeLauro and Ranking Member Tom Cole of the U.S. House Committee on Appropriations, Subcommittee on Labor, Health & Human Services asking that the Committee continue to make investments in programs that help ensure older Americans can live independently and with dignity as they age.  Specifically, AARP urged investment in the programs associated with the Social Security Administration Operations, the Centers for Medicare and Medicaid Services, and the Administration for Community Living. (PDF)

L: On June 21, 2022 AARP sent a letter to Chair Ron Wyden and Ranking Member Mike Crapo of the U.S. Senate Committee on Finance expressing support for the provision in the Enhancing American Retirement Now (EARN) Act of 2022 allowing more of the 27 million employees across the country who work part-time to enroll in workplace retirement plans sooner. This bill would reduce the requirement for part-time workers to participate in an employers’ retirement savings plan from three years of service down to two years. (PDF)

C: On June 20, 2022 AARP sent a letter to Chair Richard Neal and Ranking Member Kevin Brady of the U.S. House Committee on Ways and Means providing comments with regard to a hearing the committee is holding on The Burnout Epidemic and What Working Women Need for a Stronger Economy. AARP believes that job-protected leave, such as paid family and caregiving leave, will enable all women, including those age 50 plus, to remain in the workforce for as long as they choose. (PDF)

L: On June 13, 2022 AARP sent a letter to Chair Patty Murray and Ranking Member Richard Burr of the U.S. Senate Committee on Health, Education, Labor and Pensions in support of the provision in the RISE & SHINE Act allowing more of the 27 million employees across the country who work part-time to enroll in workplace retirement plans sooner. This Act would reduce the requirement for part-time workers to participate in an employers’ retirement savings plan from three years of service down to two years. (PDF)

C: On June 2, 2022 AARP sent a letter to the National Highway Traffic Safety Administration in response to a request for comments on proposed changes to the National Highway Traffic Safety Administration’s New Car Assessment Program (NCAP). AARP strongly supports NHTSA’s decision to modernize the NCAP, which not only empowers consumers to better understand the safety features of new vehicles, but also encourages manufacturers and suppliers in the auto industry to develop and adopt innovative safety features into their fleets. It is essential that the NCAP promote the highest standards of safety for all road users. AARP believes that the current proposal is an important step in that direction, but that more needs to be done. (PDF)


C: On May 27, 2022 AARP sent a letter to the U.S. Department of Transportation providing comments in response to a notice of proposed rulemaking concerning Accessible Lavatories on Single-Aisle Aircraft. Individuals with mobility impairments, many of whom are older adults, need access to safe and convenient transportation options, including air travel. Unfortunately, the lack of accessible lavatories on single-aisle aircraft presents a significant barrier to air travel for millions of people. (PDF)

C: On May 26, 2022 AARP sent a letter to the Internal Revenue Service providing comments in response to the IRS’s proposed regulation for an exception, if certain requirements are met, to the application of the ‘‘unified plan rule’’ for Multiple Employer Plans (“MEP”) in the event of a failure by one or more employers participating in the plan. AARP applauded the IRS for striving to issue rules that improve retirement savings coverage by ensuring that one participating employer failure does not cause disqualification of a MEP for all employers maintaining the plan, but did offer some additional protections for plan participants. (PDF)

L: On May 18, 2022 AARP sent a letter to Chairman John Larson and Ranking Member Kevin Hern of the House Ways & Means Committee, Subcommittee on Social Security thanking them and the members of the Social Security Subcommittee for holding an important hearing on “Strengthening Social Security’s Customer Service.” AARP is calling on Congress and the President to provide no less than the full $15.156 billion appropriations amount requested by Acting Commissioner Kijakazi for FY 2023, in order to make necessary service improvements at the agency. (PDF)

L: On May 17, 2022 AARP sent a letter to Speaker of the U.S. House of Representatives Nancy Pelosi and House Republican Leader Kevin McCarthy in support of H.R. 7309, the Workforce Innovation and Opportunity Act of 2022 (WIOA). This reauthorization bill will strengthen the federal workforce development system and address misperceptions of age and assist older job seekers with training and job placement. (PDF)

L: On May 16, 2022 AARP sent letters to Chairwoman Rosa DeLauro and Ranking Member Kay Granger of the U.S. House Committee on Appropriations, and to Chairman Patrick Leahy and Ranking Member Richard Shelby of the U.S. Senate Committee on Appropriations. The purpose of the communications was to urge both Committees to fully fund the Social Security Administration in fiscal year 2023. For years, the agency has been plagued with serious customer service deficiencies as a result of chronic underfunding. (House – PDF)(Senate – PDF)

C: On May 9, AARP submitted comments re: FINRA Regulatory Notice 22-08 relating to complex products. AARP encouraged FINRA to update their regulatory framework to account for the proliferation of individual consumers accessing complex investments directly via self-directed investment platforms, without the assistance of a financial professional. AARP reiterated that regulatory agencies need to meet consumers where they are, disclosures need to be accessible and understandable, and consumer protections must be robust and appropriate to the type of investments made by consumers. (PDF)

L: On May 3, 2022 AARP sent a letter to U.S. Senators Sherrod Brown (D-OH) and Rob Portman (R-OH) endorsing the SSI Savings Penalty Elimination Act. This legislation would make long-overdue updates to the asset limits under the Supplemental Security Income (SSI) program, encourage personal savings among SSI beneficiaries, and increase access to financial assistance to those who are most in need, including older Americans. (PDF)

L: On May 2, 2022 AARP sent a letter to U.S. Senators Michael Bennet (D-CO) and Rob Portman (R-OH) in support of the Evictions Crisis Act (S. 2182), which would help promote stable housing for millions of low-income renters and their families across the country. This bipartisan legislation addresses a serious and growing problem affecting millions of Americans, and increasingly impacting older adults. (PDF)


C: On April 29, 2022 AARP submitted comments to the Federal Highway Administration in response to a request for information concerning the implementation of the Infrastructure Investment and Jobs Act (IIJA). The significant levels of investment provided by the IIJA offers a historic opportunity to provide a safer and more accessible transportation system to help meet the diverse needs of our members and all Americans. In the comments, AARP noted five goals for transportation that the FWHA should focus on:  enhancing mobility, ensuring affordability, securing equity, prioritizing accessibility, and supporting sustainability and healthy living. (PDF)

C: On April 13, 2022 AARP submitted a letter to the Employee Benefits Security Administration with comments on the U.S. Department of Labor’s proposal to amend its procedures governing the filing and processing of prohibited transaction exemption applications. AARP supports the changes to the Prohibited Transaction process because it focuses on the interests and protection of participants and beneficiaries. In particular, AARP supports the requirement that an independent appraiser, auditor or accountant would need to include a signed and dated declaration under penalty of perjury that, to the best of its knowledge and belief, all of the representations made in any statement supporting the exemption are true and correct. (PDF)

C: On April 11, 2022 AARP submitted a letter to the Consumer Financial Protection Bureau in response to the Bureau’s request for comments regarding fees imposed by providers of consumer financial products or services. Referred to as “junk fees,” such as overdraft fees or account inactivity fees, AARP provided a variety of comments about these types of fees, as the CFPB looks to act decisively to reign in such anti-consumer practices. (PDF)


S: On March 31, 2022 Shannon Guzman, MCP, Senior Strategic Policy Advisor in the AARP Public Policy Institute provided testimony on behalf of AARP before the U.S. Senate Committee on Banking, Housing, and Urban Affairs for a hearing entitled “Affordability and Accessibility:  Addressing the Housing Needs of America’s Seniors.” The current state of housing is precarious for too many older adults and their families, threatening their quality of life. As the older adult population grows in the years ahead, concrete steps are needed at all levels and throughout society to prepare to meet the housing needs of older adults. (PDF)

L: On March 28, 2022 AARP sent a letter to Chairman Richard Neal and Ranking Member Kevin Brady of the U.S. House Committee on Ways and Means, and Chairman Robert Scott and Ranking Member Virginia Foxx of the U.S. House Committee on Education and Labor in support of the Securing a Strong Retirement Act of 2022. While Social Security continues to be the bedrock of retirement income for most American workers and their families, individuals want and need additional retirement income sources. This bipartisan legislation would make several significant enhancements to current law. (PDF)

C: On March 24, 2022 AARP submitted Reply Comments to the Federal Communications Commission in the matter of Empowering Broadband Consumers Through Transparency.  AARP’s review of the opening comments reveals widespread support among consumer advocacy groups, as well as individual consumers, for broadband labels in the spirit of those contained in the 2016 Public Notice. Major service providers concede that the Commission must adopt labels, and smaller Internet Service Providers (ISPs) voice support the use of labels. As noted by Consumer Reports, et al., the essential nature of broadband services require clear labels to cut through the confusing practices employed by some ISPs. (PDF)

L: On March 9, 2022 AARP sent a letter to the U.S. Equal Employment Opportunity Commission and the Office of Federal Contract Compliance Programs concerning the launch of the Hiring Initiative to Reimagine Equity (HIRE) to help address key hiring and recruiting challenges that prevent or impede underrepresented communities from accessing good jobs. Given AARP’s long history of fighting to remove hiring barriers based on discrimination particularly for older jobseekers, AARP officially requested the opportunity to be included in this initiative on behalf of older workers. (PDF)

C: On Wednesday, March 9, AARP filed comments in response to the FCC’s recent Notice of Proposed Rulemaking (NPRM), which sought comment on a requirement that broadband providers display simple-to-understand labels that disclose, at the point of sale, accurate information about prices, introductory rates, data allowances, broadband speeds, and management practices, among other things. As a result, these “broadband nutrition labels”, included in last year’s bipartisan infrastructure law will promote competition among broadband providers now that this information is readily available, including help lower prices for consumers and help decrease levels of fraud by providers (hidden fees, introductory vs. long term monthly fees etc.). IIJA requires the FCC to adopt broadband consumer label rules by November 2022. (PDF)


L: On February 17, 2022 AARP sent a letter to U.S. Senators Kyrsten Sinema (D-AZ), Chuck Grassley (R-IA), Ron Wyden (D-OR) and Mike Crapo (R-IN) endorsing the Improving Social Security’s Service to Victims of Identity Theft Act. The Act would streamline and improve the assistance provided by the Social Security Administration to individuals whose Social Security number has been stolen or misused. This would be welcomed assistance for victims of these crimes who are caught in an often overwhelming situation. (PDF)

C: On February 4, 2022 AARP summited formal comments to the U.S. Department of Commerce, National Telecommunications and Information Administration (NTIA) in the matter of Infrastructure Investment and Jobs Act Implementation. Under this Act, the NTIA is being entrusted with the oversight of a significant and potentially transformational investment to achieve the goal of universal broadband access and adoption. The NTIA will be administering some of the largest grant programs for broadband deployment ($42.45 billion) and Digital Equity ($2.75 billion), which will determine how funds are awarded and monitored. AARP’s comments urges the NTIA to mine existing federal and state broadband grant frameworks to identify a set of best practices and also to be willing to adapt its rules as it (and states) gains additional experience. (PDF)


L: On January 19, 2022 AARP sent a letter to U.S. Senators Chris Van Hollen (D-MD), Tim Scott (R-SC), Raphael Warnock (D-GA), and Cynthia Lummis (R-WY) expressing support for the Empowering States to Protect Seniors from Bad Actors Act. The Act would provide older Americans with a new defense against financial exploitation and investment scams tailored to exploit them. Specifically, the bill would implement and modernize the Senior Investor Protection Grant Program, established by law in 2010. (PDF)