We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.
In The News: Want To Make Payday Loans In States Where It’s Outlawed? Rent A Bank! (Talking Points Memo)
FDIC Chair Jelena McWilliams “is doing the bidding of loan sharks who have a decades-long history of trying to get around state consumer protection rules,” Americans for Financial Reform spokesperson Carter Dougherty observed. “And now a federal regulator is helping them do it.”
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