View or download a PDF of the coalition letter here.
View or download a PDF of the AFREF comment letter here.

The Americans for Financial Reform Education Fund (AFREF), along with 37 labor unions, investors, and advocacy organizations, submitted a comment letter to the Federal Deposit Insurance Corporation (FDIC) in support of their proposal to strengthen regulations under the Change in Bank Control Act (CBCA). The coalition letter highlights broad organizational support for the FDIC’s proposal to remove the exemption from the notice requirement for acquisitions of voting securities of holding companies with FDIC-supervised subsidiaries. It also 1) provides background on the role large asset managers play in the governance of public companies, 2) addresses some of the questions in the Notice of Proposed Rulemaking regarding the presumption of control triggered when an entity owns, controls, or holds the power to vote 10 percent or more of any class of voting securities, and 3) makes the case for the Financial Stability Oversight Council (FSOC) to holistically address the financial stability threats posed by asset manager concentration and power.

The AFREF comment letter expands on these issues and recommendations.