Category Archives: Letters to Regulators

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AFR Comment Letter to CFPB on High Cost Mortgage Loans

AFR submitted a comment letter to the CFPB on their proposed rules implementing Dodd-Frank changes regarding high cost mortgage loans. The letter argues against changing triggers for high cost loans for smaller loans ­ which the statute allows but does not require, and argues that the proposal should be strengthened in various ways, including by making sure that borrowers in revolving lines of credit get the same protections as those in closed end mortgages.

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AFR Comment Letter: Designation of Swaps that Must be Cleared

AFR submitted a comment letter to the CFTC on the clearing mandate. This is the CFTC’s initial proposal for what derivatives will have to be cleared, and the CFTC has the ability to designate more swaps for clearing, which AFR recommends in the letter.

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AFR Comment Letter: CFTC Derivatives Rules Must Apply to Foreign Affiliates

AFR submitted a comment letter to the CFTC regarding a rule that will determine whether the CFTC can regulate derivatives trading by foreign affiliates of US banks and corporations. Since derivatives trades move easily around the world and between affiliates and the parent company, it is important that US regulators be able to apply Dodd-Frank to such foreign trades. Our letter urged the CFTC not to let financial institutions escape derivatives rules by funneling transactions through their foreign affiliates.

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Sign on Letter: JOBS Act Rulemaking Raises Complex Concerns

The JOBS Act rulemaking on the SEC’s schedule Aug. 22 raises a variety of complex issues that demand a full and transparent rulemaking process. The rushed approach to rulemaking reportedly contemplated by the agency would not allow for full consideration of these issues, and would therefore put investors at risk.