The AFR Education Fund wrote to the FDIC urging them to maintain comprehensive disclosure requirements for securitizations that are backed by depository banks. The agency is proposing to exempt private offerings from these requirements. Most of the toxic mortgage securitizations sold prior to the financial crisis were private offerings.
Letters to Regulators: Americans for Financial Reform Education Fund letter opposing the FDIC relaxing the process of resolution planning for Insured Depository Institutions
Americans for Financial Reform Education Fund raised concerns over weakening resolution planning requirements intended to prepare large bank holding companies for an orderly resolution in conventional bankruptcy without risk to financial stability and without any reliance on extraordinary public support of the failed bank or its counterparties.
Letters to Regulators: Americans for Financial Reform Education Fund letter opposing banking regulators weakening big banks’ resolution planning requirements
Americans for Financial Reform Education Fund sent a letter to banking regulators opposing a proposal that would make the resolution planning process substantially less stringent than it currently is, and raising concerns over the safety and soundness of individual banks and the effect on U.S. financial stability.
Letters to Regulators: Bank regulators should not weaken prudential rules for U.S. operations of foreign banks.
Regulatory agencies purport to “tailor” prudential rules, but they are severely undermining capital and liquidity requirements for foreign banks operating in the U.S.
Several safeguards are critical to ensure that bank loan programs—particularly those designed for financially distressed consumers—promote financial inclusion rather than exacerbate financial exclusion and distress.
The need for strong public interest nominees is even greater today. This Administration has been
filling key regulatory positions with people pursuing Wall Street’s agenda at the public’s expense,
and the revolving door is spinning faster than ever. There is an enormous amount at stake at both
the SEC and FDIC as the financial industry and their friends in the Trump administration work to
undo the progress made in Dodd-Frank and to undermine key investor protection standards.
AFR sent an opposition letter to HR 2148, which would have put loopholes in new rules designed to ensure that banks did not make excessively risky commercial real estate loans. HR 2148 Oppo letter
AFR sent the letter below to the House Financial Services Committee urging them to reject nineteen deregulatory bills. AFR Letter Re HFSC 10-11 Markup
“ILC charters exploit a loophole in federal banking laws to gain access to the federal deposit-insurance safety net while avoiding critical federal supervision and regulation. ILCs therefore pose unique risks to the financial system… If these applications are granted, [it] will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications, potentially unleashing a dangerous avalanche of new applications.”
“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”