Category Archives: Education Fund

Events: Alexa Philo, AFR’s Senior Policy Analyst, Testifies Before the House Financial Services’ Subcommittee on Financial Institutions and Monetary Policy

Increased capital requirements in the Fed, FDIC, and OCC’s Large Bank proposal strengthen the banks’ ability to withstand stresses that would otherwise imperil their financial viability and hurt depositors, customers and the economy. Robust capital levels prevent financial crises that have vastly disproportionate impacts on Black, LatinX and other underserved communities. AFR strongly urged the agencies to move forward on these proposals as more well-capitalized banks are better able to provide credit to customers and communities, advancing economic justice and helping the economy to work better for everyone.

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Letters to Congress: Letter of Opposition to Four Anti-ESG Legislative Proposals

AFR sent a letter in opposition to four legislative proposals that the House Committee on Education and the Workforce is scheduled to consider at its September 14th Full Committee Markup. These bills’ amendments to the Employee Retirement Income Security Act (ERISA) would undermine workers’ retirement security and are part of a broader political campaign against common sense investment practices. The campaign seeks to force financial actors to ignore a slew of financial risks regardless of the consequences for workers’ retirement security and the integrity of our financial system.

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Letters to the Regulators: Letters to the Financial Stability Oversight Council in Support of Increased Supervision of Nonbank Companies and Revising the Analytic Framework for Assessing Financial Stability Risk

AFREF submitted comment letters to the Financial Stability Oversight Council (FSOC) on two proposals that would strengthen its toolbox for addressing threats to financial stability, including those related to climate change, and make it easier to designate nonbank companies like asset managers and insurance companies as systemically important institutions that need enhanced regulation by the Federal Reserve Board.

The letters detail how threats to financial stability from nonbank financial institutions are growing, and it encourages FSOC to quickly strengthen and finalize its proposals to be able to respond effectively and proactively to emerging risks. Many nonbank financial institutions already face heightened stress from large climate-related shocks, including several major insurers’ recent decisions to withdraw coverage from many states and zip codes. Insurance companies, asset managers, private equity firms, and other nonbank financial institutions are also creating significant risks to the financial system through their insured or financed emissions — risks that are often forced upon other financial institutions and consumers who will struggle to manage them.

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Letters to the Regulators: Letter to PCAOB Supporting Proposed Audit Standards to Report Noncompliance with Laws and Regulations, Including Climate Regulations

AFREF joined Public Citizen in a comment urging PCAOB to strengthen and swiftly finalize its proposed updated audit standards around reporting noncompliance with laws and regulations and identifying risks of material misstatement in financial statements. Climate-related accounting fraud is on the rise, and many companies are misrepresenting their financial position by underestimating their asset retirement obligations and environmental liabilities, and failing to substantiate public climate commitments in their financial statements and SEC filings. 

The proposed regulatory updates from PCAOB would strengthen auditors’ responsibilities to identify and report these types of misstatements and fraud and provide a significant benefit to investors by catching costly noncompliance issues early before they harm financial performance, and to the public by deterring corporate law-breaking and noncompliance.

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Letters to Congress: Letter Opposing Anti-ESG Bills

Americans for Financial Reform sent a letter to the House Financial Services Committee opposing bills that undermine shareholders’ ability to make sound financial decisions and hold corporations accountable. In our letter, we provide an overview of the bills noticed during the various ESG hearings and briefly discuss why we oppose them.

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Letters to the Regulators: Letter to the SEC Supporting the Prohibition of Conflicts of Interests in Securitization

Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission (SEC) supporting its proposal to prohibit conflicts of interest in securitizations. Such conflicts were at the heart of the Great Financial Crisis of 2008 leading to trillions of dollars in losses across the financial system and irreparable harm to millions of homeowners. Now, with the growth in securitizations such as those backed by commercial real estate and other assets, the SEC’s proposals can ensure that similar practices do not happen again at the harm of investors and others.

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lawyer signing a document Photo by Helloquence on Unsplash

Letters to Regulators: Comment on OIRA Cost Benefit Analysis Guidance

AFREF submitted comments to the Office of Information and Regulatory Affairs on its proposal to modernize the regulatory process to better account for racial and economic inequality, climate change, and other factors within economic analysis; and improve transparency and empower and benefit members of marginalized communities through the regulatory process.

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