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Letters to Regulators

Letters to Regulators: AFR sent a letter to the U.S. Commodity Futures Trading Commission criticizing a new de minimis threshold proposal
August 14, 2018 – 9:33 am

The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC …

Joint Letter: SEC Broker Proposal Fails To Establish Strong Standard or Mitigate Conflicts
August 7, 2018 – 11:10 am

The rule’s most significant failing is that it does not establish a clear uniform best interest standard, one that is no less stringent than that found in the Investment Advisers’ Act, for all professionals who provide investment advice to retail clients. Instead, it adopts a weaker standard for broker-dealers that falls short of a true best interest standard and does not adequately address the conflicts of interest that too often are permitted to taint broker-dealers’ recommendations.

Letters to Regulators: AFR commented on Federal Reserve, OCC, FDIC proposed rule regarding the implementation of CECL accounting rules.
July 13, 2018 – 11:00 am

Americans for Financial Reform sent a letter to the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation commenting on a proposal …

Letters to Regulators: AFR commented on a proposal that would cut the minimum required leverage ratio at the largest U.S. banks.
June 26, 2018 – 11:32 am

Americans for Financial Reform sent a letter to the Federal Reserve Board of Governors and the Office of the Comptroller of the Currency to comment on a proposal that would reduce the minimum leverage ratio …

Letters to Regulators: AFR commented on Federal Reserve proposed changes to capital rules to implement new stress buffer requirements.
June 26, 2018 – 11:18 am

AFR commented on a Federal Reserve proposal that would integrate the capital requirements in its different capital regimes to institute new stress buffer requirements.

Joint Letter: 25 Organizations Write Dept of ED on Evaluating Undue Hardship Claims in Student Loan Bankruptcy
May 24, 2018 – 3:33 pm

AFR was among 25 organizations that signed-on to comments by the National Consumer Law Center on evaluating undue hardship claims in student loan bankruptcy. You can view or download the PDF here.

Letters to Regulators: AFR opposed roll back of transparency disclosures to investors in SEC proposed rule “Investment Company Liquidity Disclosures.”
May 22, 2018 – 12:03 pm

AFR commented on the roll back of transparency disclosures to investors in the SEC proposed rule “Investment Company Liquidity Disclosures.”

Joint Letter: 8 Organizations Warn Regulators Against Bank Payday Loans and Rent-a-Bank Arrangements
May 15, 2018 – 6:25 pm

“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”