Category Archives: Financial Reform News

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AFR’s Comment to the FDIC and Federal Reserve on Resolution Plans

AFR submitted a comment to the FDIC and the Federal Reserve on the rules implementing the Dodd-Frank requirement that companies submit “living wills” and records of credit exposures. “Living Wills” are plans detailing how the company could be resolved through the bankruptcy process without a need for government intervention. AFR supported the rules but suggested they be strengthened by requiring planning for situations of market stress and also by establishing more thorough and continuous records of credit exposures.

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This Week in Wall Street Reform

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Call Your Senators Right Now

Senators could be voting today on proposals to gut the CFPB and to repeal ALL of the progress we made on financial reform. In a last minute development, opponents of financial reform are pushing for votes TODAY on amendments to gut the new Consumer Financial

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AFR Opposes Exempting Forex Swaps and Forwards from Clearing and Exchange Requirements

AFR submitted a joint comment with Professor Michael Greenberger of the University of Maryland on Treasury proposal to exempt foreign exchange swaps and forwards from clearing and exchange trading requirements under Dodd-Frank. The letter pointed out that Treasury had not provided any evidence supporting its case that foreign exchange derivatives did not pose systemic risk, and in fact there is very strong evidence from the 2008 financial crisis and today that they do pose such risks.

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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.

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AFR Calls for Strengthening in Oversight Rules

AFR submitted a comment letter to the banking oversight agencies on proposed rules to change pay practices at big banks. The rules include a number of proposals, including mandatory deferral of some compensation, intended to ensure that Wall Street executives are financially accountable for the long-term consequences of their actions. The letter commended a number of positive steps taken in the proposal, but made the case that the deferral and oversight rules would have to be strengthened to fully address the problem.