Letters to Congress
“The first five-and-a-half years of the CFPB’s history has vindicated the decisions that Congress made in 2010 to create a strong independent agency to protect consumers from fraud and abuse in the financial marketplace. …It’s action have begun to reform the industry by making banks andother financial services companies more attentive to consumers’ rights…”
We, the undersigned organizations, representing millions of Americans, are writing to urge you to oppose the nomination of Steven Mnuchin as Secretary of the Treasury.
“This legislation is transparently an effort to paralyze the SEC and to empower Wall Street lawyers to overturn its decisions, not to improve its analysis or decision making. …The most prominent new requirement would mandate that the SEC identify every “available alternative” to a proposed regulation or agency action and quantitatively measure the costs and benefits of each such alternative prior to taking action. …In addition to the enormous task of identifying and analyzing every available alternative to a course of action, the agency would be required to perform half a dozen new analyses in addition to its current requirements concerning market efficiency, competition, and capital formation. These new requirements include analyses of effects on small business, market liquidity, state and local government, investor choice, and “market participants”. Notably, no new requirements concerning the protection of investors or preventing another financial crash are included. …We urge you to reject it.”
“By freezing the CFTC’s funding at its current inadequate level for the next five years, this legislation exacerbates the agency’s most fundamental problem – a lack of resources to accomplish its mission. After the 2008 financial crisis, the CFTC became newly responsible for hundreds of trillions of dollars in previously unregulated swaps markets. …Even as it fails to address the pressing problem of funding, HR 238 would also load down the CFTC with additional mandates that would drain resources and act as a roadblock to necessary oversight and enforcement.
“The REINS Act is radical legislation that would upend decades of administrative law practices dating back to the New Deal era in the 1930s. The bill requires explicit approval of any ‘major regulation’ by both the House and Senate within 70 days in order for that rule to take effect. This requirement would create crippling barriers to administrative actions necessary to protect the public and implement the law.”
AFR joins 19 other organizations to express our opposition to H.R. 6392, the “Systemic Risk Designation Improvement Act of 2015.” This legislation increases the likelihood of big bank failures that could put at risk the economic security of millions of families.
“Far from improving systemic risk regulation, this legislation increases the likelihood of big bank failures that could put at risk the economic security of millions of families. It puts unprecedented new constraints on the ability of the Federal Reserve to provide basic oversight of large bank holding companies, including provisions that grant an unaccountable council of international regulators statutory powers over U.S. regulatory decisions. It would also politicize bank regulatory decisions, granting the Treasury Secretary of the incoming Administration new powers to pick and choose which big banks must follow basic safety rules.”
“The budget is not the place to try to force through provisions that are dangerous to economic stability or to families economic security, would not pass alone, or that the President would likely veto. We strongly urge Members of Congress to oppose any flawed funding proposals that undermine the CFPB, the Dodd-Frank Act, the DOL’s conflict-of-interest rule, or other financial reform and accountability legislation or regulations.”