Read AFR’s comment letter in response to regulators posing the questions of whether stable value contracts meet the definition of swaps in the Dodd-Frank Act, and, if so, whether they should be regulated as swaps or given an exemption. The letter points out that stable value contracts have the characteristics of swaps and also pose some of the same risks as swaps do. It does not take a specific position on whether stable value contracts should be subject to all swaps regulation, but does urge regulators to address these dangers by extending business conduct standards to issuers of stable value contracts and also to ensure that issuers of financial guarantees have sufficient resources to back up their promises.

Harmonious international financial regulation is best achieved by the timely implementation of Dodd-Frank-mandated regulations for derivatives. Contrary to claims made by Wall Street and its allies, postponing the implementation of Dodd-Frank rules until the global community reaches a consensus on derivatives regulation would undercut efforts to achieve harmonious financial reform and expose American taxpayers to significant economic risk.

Click here to view this week’s highlights and lowlights in Wall Street Reform – September 17, 2011 – September 23, 2011.

Click here to view this week’s highlights and lowlights in Wall Street Reform – September 10, 2011 – September 16, 2011.

Click here to view the full letter to Senators about the importance of full funding for the SEC and CFTC.

Read AFR’s letter urging members of the Senate Appropriations Committee to vote “No” on any amendments that would undermine the CFPB through the appropriations process.