Letters to Regulators
“Americans for Financial Reform supports the separation of banking and commerce as a foundational principle, motivated both by considerations of preserving fairness in competition with non-bank firms who do not have access to the prudential safety net, and by considerations of financial safety and soundness.”
AFR submitted a comment to the Consumer Financial Protection Bureau offering some suggestions on how to strengthen their proposed rule on defining “larger participants” in the international money transfer market. This proposed rule, if adopted, would be the fourth in a series of rulemakings to define ‘larger participants’ in various consumer financial product markets. AFR’s recommendations include expanding the criteria CFPB uses to define larger participants, and covering domestic as well as international money transfers under their supervisory purview.
AFR, AFSCME, and the SEIU today sent the letter below to the Securities and Exchange Commission calling on the Commission to reproprose and strengthen its rules governing credit rating agencies. Conflicts of interest and deceptive practices at credit rating agencies were central to the 2008 financial crisis and continue to pose a threat to the economy today.
AFR and more than 100 consumer, civil rights, labor and community organizations submitted a letter to the CFPB urging the Bureau to issue a strong rule to address unfair, deceptive or abusive practices in the payday and small dollar loan market.
AFR submitted a comment to The Fed voicing concerns over the very weak proposal on emergency lending. In the letter we recommend that the Federal Reserve place specific advance limits on the length of time that an institution can rely on emergency lending, as well as better controls to limit lending to truly solvent institutions.
AFR submitted a comment letter to the CFTC, urging that they maintain oversight of derivatives transactions in the United States.
AFR submitted a letter to the SEC expressing deep concern that the rules proposed by the Commission regarding the JOBS Act fail to deliver important investor protections.
AFR submitted a comment letter to the financial stability board on plans for the aggregation of global derivatives data.