Home » Archive by Category

Letters to Regulators

Letter to Congress: AFR, 32 Organizations Express Concern over CEO Bonus Pay Loophole
July 22, 2016 – 4:07 pm

“We appreciate the opportunity to comment on the proposed rule regarding incentive compensation in the financial industry. This proposal is a significant improvement over the 2011 version… However, we remain deeply concerned that loopholes in the regulation will allow a reckless Wall Street bonus culture to continue, putting taxpayers and the broader economy at risk.”

Letter to Congress: AFR Opposes The Financial CHOICE Act
July 12, 2016 – 9:16 am

“On behalf of Americans for Financial Reform (AFR), we are writing to express our very grave concerns about the “Financial CHOICE Act” and to urge you to oppose this measure. Passage of this legislation would have a devastating effect on the ability of regulators to protect consumers and investors from exploitation and the economy from financial risk. It would expose consumers, investors, and the public to greatly heightened risk of abuse in their regular dealings with the financial system, and our economy as a whole to heightened risk of instability and crisis. “

Letter to Regulators: AFR Comments on Consultative Document that would Change Derivatives Risk Exposure
July 6, 2016 – 2:41 pm

“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the above mentioned Consultative Document. Among other issues, this Consultative Document proposes to change the measurement of derivatives risk exposures for leverage ratio purposes by replacing the Current Exposure Method (CEM) used today with the Standardized Approach to Counterparty Credit Risk (SA-CCR). The document implies that the SA-CCR has a more realistic approach to risk measurement, while the CEM is more conservative.”

Letter to Regulators: AFR and Committee for Better Banks Urge Improvements to Consumer Compliance Ratings
July 5, 2016 – 5:48 pm

“Americans for Financial Reform (“AFR”) and the Committee for Better Banks (“CBB”) appreciate the opportunity to comment on the Federal Financial Institutions Examination Council (“FFIEC”) notice of proposed revisions to the Uniform Interagency Consumer Compliance Rating System (“CC Rating System”).”

Letter to Regulators: AFR, 21 organizations call on FHFA to include language preference on mortgage applications
June 24, 2016 – 12:43 pm

“We are writing in response to the letter you received recently from a number of industry trade groups opposing the inclusion of preferred language data fields in the redesigned Uniform Residential Loan Application (URLA)… The URLA redesign presents a unique and unprecedented opportunity to take an important first step towards addressing equitable access to the mortgage market for LEP consumers and we strongly urge you to include preferred language data fields.”

Letter to Regulators: AFR Comments on the Fed’s Proposed Rule on Credit Limits
June 22, 2016 – 2:26 pm

“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the Federal Reserve Board’s (the “Board”) Notice of Proposed Rulemaking (“Proposed Rule” or “Proposal”) on the above-mentioned rule. Section 165 of the Dodd-Frank Act mandates the imposition of single counterparty credit limits (SCCL), and significantly expands the range of exposures that are captured under such limits. This Proposed Rule is a re-proposal of the Board’s original 2011 proposal regarding credit exposure limits, and makes a number of changes to the original proposal. ”

Letter to Regulator: AFR Comments to Basel Committee On Bank Transparency
June 15, 2016 – 1:12 pm

“Given the complexity of the regulations now applying to global banks, a comprehensive new set of disclosures is absolutely necessary in order to help both investors and civil society organizations such as ourselves understand bank activities. A clear and consistent set of public disclosures should also be helpful for financial regulators, who under the U.S. system do not always have access to bank supervisory data that may be relevant to the markets they oversee.”

Letter to Regulators: AFR, 71 Orgs Submit Comment on proposed student loan “Payback Playbook”
June 13, 2016 – 2:05 pm
Letter to Regulators:  AFR, 71 Orgs Submit Comment on proposed student loan “Payback Playbook”

“We commend the agencies for their work in compiling this series of potential borrower communications – the
Student Loan Payback Playbooks. It benefits borrowers, servicers, and the agencies to ensure that
federal student loan borrowers are aware of options that will make their student loan payments
affordable and allow them to remain current on their loans.”