AFR Bulletin: Prudential Standards for End User Derivatives
View Our PDF Version Here
Category Archives: Financial Reform News
AFR Comment Letter to the SEC on Credit Ratings
Read pdf here. April 25, 2011 Ms. Elizabeth Murphy Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 Re: RIN 3235-AL02: “Proposed Amendments to Remove References to Credit Ratings in Rule 2a-7 Under The Investment Company Act of 1940” Dear Ms.
WTO Financial Deregulation
Read pdf here. April 21, 2011 The Honorable Michael Punke Ambassador Deputy U.S. Trade Representative and Permanent Representative to the WTO Permanent Mission of the United States of America 11 Route de Pregny 1292 Geneva Dear Ambassador Punke: Even as outcomes of intensified efforts
AFR Bulletin: Position Limits
Financial speculation on commodities like oil and food is driving up consumer prices from the gas pump to the grocery store. To bring it under control, we need workable position limits. But the verdict is in – the CFTC’s proposal needs to be strengthened to do the job.
AFR Response to Misleading Study on Servicer Settlement
The bank-funded study on the supposed economic costs of the state AGs proposed settlement with mortgage servicers is a patchwork of unsupported assumptions all designed to lead to one conclusion – that the big servicers who funded the study ought to get a free ride.
AFR Private Funds Letter
View Our PDF Version Here April 12th, 2011 Elizabeth M. Murphy Secretary Securities and Exchange Commission 100 F St., NE Washington, DC 20549 Mr. David A. Stawick Secretary Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington DC 20581 RE:
AFR Market Risk Letter
This NPR implements provisions of the Basel III agreement relevant to the use of internal risk modeling to set risk-based capital levels for financial institutions. As a general matter, AFR is highly skeptical of the use of internal bank Value at Risk (VAR) models for setting capital requirements.
AFR to Congress: Protect Homeowners, Hold Lawbreaking Big Banks Accountable
Read the pdf here. April 13th, 2011 Dear Representative, The record of lawbreaking and abuse by the largest banks and servicers at every stage of the mortgage origination, securitization, servicing and foreclosure process is breathtaking, and the damage done – to homeowners, communities, investors, pension
US PIRG’s Big Banks, Bigger Fees: A National Survey of Bank Fees and Fee Disclosure Policies
Since Congress largely deregulated consumer deposit (checking and savings) accounts beginning in the early 1980s, the PIRGs have tracked bank deposit account fee changes and documented the banks’ long-term strategy to raise fees, invent new fees and make it harder to avoid fees.
AFR SEC SEF Letter
A key objective of Title VII of the Dodd-Frank Act (DFA) is to create transparency in previously unregulated derivatives markets. Indeed, the transparency goal is apparent in the short title of the section – ―The Wall Street Transparency and Accountability Act‖. Transparency is a critical goal across the entire Dodd-Frank Act, and is mentioned in the overall purpose statement of the legislation.