Letters to Regulators
“We, the undersigned 51 organizations, are writing to express our strong support for the Department of Labor’s (DOL’s) conflict of interest or “Fiduciary Duty” rule and our strong opposition to eliminating or weakening the rule. …
“AFR strongly supports measures to both limit and control risks of physical commodity involvement at financial holding companies. …Specifically, we support the new consolidated limits on the total size of commodity holdings, the capital increase to 300 percent risk weights applied to commodities held under 4(k), and more…”
“…The digital economy should ensure consumers can access and use records about themselves, and that consumers can choose to authorize third-parties to access such data on their behalf to support their financial health and facilitate competition among financial services providers.”
We along with more than 250 organizations separately submitted a letter urging the OCC to refrain from issuing charters to nondepository fintech lenders because doing so would enable the chartered entities to avoid state interest rate caps and other state consumer protection laws, as well as state oversight, thereby putting consumers and small businesses at risk.
“State laws often operate as the primary line of defense for consumers and small businesses; thus, the proposal puts them at great risk. The OCC must not undermine state rate caps. Interest rate caps are the simplest, most effective way to protect borrowers from unaffordable, high-rate loans and to align the interests of lenders and borrowers.”
We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.
We are deeply concerned that the Investment Company Institute (ICI) Letter lays out a set of changes to the Proposed Rule which wold effectively negate the derivatives exposure limits in the rule and render them useless as a tool for controlling speculative leverage at registered funds, as is required by the 1940 Act. …This change would not simply modify the relative weighting of derivatives exposures, but would result in a massive increase in the absolute limit on derivatives risk exposure.
AFR joined with the AFL-CIO in calling on the Securities and Exchange Commission to revise its proposed rule so that “any changes to the Commission’s disclosure rules do not narrow the scope of information that is provided to investors.”