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Letters to Regulators

Joint Letter: AFR Joins 26 Allies in Applauding DOL’s Commitment to Fiduciary Rule
February 25, 2015 – 1:28 pm

“As organizations that support strengthening protections for retirement savers, we write to thank you for sending a proposed rule to the Office of Management and Budget (OMB) to update and close loopholes in the 40-year-old rules that apply when individuals receive professional advice about retirement investments. Updating protections for retirement savers is urgently needed and long overdue.”

IATP / AFR Comment on Position Limits
January 22, 2015 – 9:37 am

The Institute on Agriculture and Trade Policy and Americans for Financial Reform submitted a joint comment on position limits for commodities to the Commodity Futures Trading Commission.

AFR Comment Letter: On Forward Contracts With Embedded Volumetric Optionality
January 20, 2015 – 9:48 am

Download the letter here.

Joint Letter: FCC Should Maintain Consumer and Privacy Protections for Cell Phone Users
January 15, 2015 – 12:16 pm

Don’t open the floodgates to a wave of “wrong number” calls to cell phones, say AFR, NCLC and more than 75 national and state groups in a letter urging the FCC to stand by the safeguards of the Telephone Consumer Protection Act.

Joint Letter: CFPB Moves Forward on Nonbank Auto Lending
December 8, 2014 – 10:46 am

“Supervision of nonbank auto financial institutions will bring much-needed attention to otherwise
lightly-regulated companies, will ensure compliance with consumer financial laws, and will
ensure that auto financing by banks, already subject to CFPB supervision, is not at a competitive
disadvantage.”

AFR Comment Letter: AFR calls on CFTC to Require Margin for Derivatives
December 2, 2014 – 4:28 pm

AFR calls on CFTC to require margin for derivatives.

AFR Letter: Mandatory Margin Requirements Needed for Uncleared Swaps
November 25, 2014 – 6:03 pm

“Mandatory margin requires participants in the swaps market to take full account of the risks of their derivatives transactions and provide some level of advance provisioning for such risks. The availability of properly segregated margin is clearly of enormous value in case of the default of a swaps counterparty.”

AFR Letter: CFTC and SEC Must Act Against Derivatives “De-Guaranteeing” Ploy
November 25, 2014 – 2:01 pm

“On behalf of Americans for Financial Reform (AFR), we write today to ask you to ensure appropriate regulatory oversight of derivatives transactions conducted through foreign subsidiaries of multinational Wall Street banks. In particular, we urge you to prevent the inappropriate classification of such derivatives as ‘non-guaranteed’ by the parent company, a classification which could exempt them from numerous critical derivatives regulations.”