AFR Signs on to Letter: Fully Fund the CFTC
AFR signed onto a letter with other business, consumer, and labor groups supporting full funding for the CFTC.
Tag Archives: CFTC
AFR and CFA Letter: Urge to CFTC to Impose Strong Business Conduct Standards
AFR wrote a letter to the CFTC urging them to maintain strong business conduct standards for derivatives dealers when dealing with municipalities and pension funds.
Coalition Press Statement: Consumer Federation of America – Wall Street’s Oil Speculation Clobbers Main Street’s Consumers
The oil price spike of the past year, which saw gasoline prices increase by over a dollar from the summer of 2010 to the summer of 2011, will drive household expenditures on gasoline to a record average of $2900 this year. Crude oil is about $30 higher than costs or historic trends justify, generating needlessly high prices for petroleum products that will drain about $200 billion out of the economy.
AFR’s Comment Letter Regarding Stable Value Contracts
Read AFR’s comment letter in response to regulators posing the questions of whether stable value contracts meet the definition of swaps in the Dodd-Frank Act, and, if so, whether they should be regulated as swaps or given an exemption. The letter points out that stable value contracts have the characteristics of swaps and also pose some of the same risks as swaps do. It does not take a specific position on whether stable value contracts should be subject to all swaps regulation, but does urge regulators to address these dangers by extending business conduct standards to issuers of stable value contracts and also to ensure that issuers of financial guarantees have sufficient resources to back up their promises.
AFR to CFTC: Margin and Capital Requirements Comment
The CFTC’s proposed rules on margin and capital requirements must be substantially strengthened. Specifically, the process of collecting margin must be generally improved, both in terms of quantity and quality required. The suggested revisions would not only improve the overall effectiveness of the rules, but also the fairness, as the proposed rules seems to favor swap dealers.
AFR Urges Full Funding for the CFTC
Read our letter to Congress urging that they support full funding for the CFTC in FY 2012 here.
AFR Comments on Proposal to Reopen Derivatives Regulations
AFR submitted a comment in response to the CFTC’s request for views on their overall proposed structure for regulating swaps and derivatives. The comment raised several issues concerning conflicts of interest in ownership and management of key areas of derivatives infrastructure, like clearinghouses and swaps data repositories. AFR also raised potential problems with definitions of “commercial risk” that could permit evasion of regulations.
AFR Urges Senators to Support Full Funding for the SEC/CFTC in 2012
Read the pdf here. May 4th, 2011 Dear Senator, As the Financial Services Appropriations Subcommittee begins consideration of fiscal year 2012 agency funding decisions, we want first to thank you for recognizing the role that the Securities and Exchange Commission (SEC) and Commodity Futures Trading
AFR to CFTC: Establish Position Limits for Derivatives Market
Read the pdf of our letter here. March 28th, 2011 Mr. David A. Stawick Secretary Commodity Futures Trading Commission Three Lafayette Center 1155 21st Street, N.W. Washington DC 20581 Re: RIN 3038–AD15 and 3038–AD16; Position Limits For Derivatives Dear Mr. Stawick: On behalf of Americans
CFTC Requirements for Swap Execution Facilities
Read the pdf of our letter here. March 8th, 2011 Mr. David A. Stawick Secretary Commodity Futures Trading Commission Three Lafayette Center 1155 21st Street, N.W. Washington DC 20581 Re: RIN Number 3038–AD18; Core Principles and Other Requirements for Swap Execution Facilities Dear Mr.