AFR submitted a comment to the Basel Committee, which sets international standards for minimum levels of bank equity capital, concerning the levels of required capital for the largest world banks (so called Global Systemically Important Banks, or G-SIBs). AFR believes the proposed Basel minimum capital levels for these banks are far too low, and the Committee’s own analysis implies much higher capital levels should be set for these entities.

The Securities and Exchange Commission has proposed business conduct rules for security-based swap dealers and major security-based participants that AFR and CFA have said will not be effective in ending abusive practices and do not do enough to bring transparency to this market. Of particular concern are serious shortcomings in the provisions designed to provide enhanced protections for special entities, such as municipalities and pension funds, shortcomings that all but guarantee the rules will not deliver the intended enhanced protections. In a comment letter filed with the SEC yesterday, AFR and CFA urged the agency to comprehensively revise the rules to address weaknesses in virtually every provision of the rules and make them at least as strong as those proposed earlier this year by the CFTC.

Click here to view this week’s highlights and lowlights in Wall Street Reform – August 20, 2011 – August 26, 2011.

Read our comment letter to the SEC here.

“AFR submitted comments in response to proposed guidance from the OCC addressing payday loans by banks and high-cost overdraft programs. We urged the agency to immediately take supervisory/enforcement action to stop Wells Fargo and US Bank, along with a couple of smaller OCC-supervised banks, from making payday loans. These loans undermine state laws aimed at protecting residents from high-cost loans that trap people in debt, as well as federal law aimed at protecting military service members from these loans. We also urged the OCC to at last put an end to the common bank practice of reordering customers’ transactions to drive up overdraft fees.”

Read our comment letter to the Fed regarding capital planning here.