Category Archives: Letters and Statements

seal for the US house of representatives

Statement: To the House Financial Services Committee Hearing On “The Semi-Annual Report of the Bureau of Consumer Financial Protection”

Americans for Financial Reform appreciates the opportunity to provide a Statement for the Record for the House Financial Services Committee Hearing on “The Semi-Annual Report of the Bureau of Consumer Financial Protection.” In the thirteen years since its creation, the Consumer Financial Protection Bureau has and continues to vigorously protect consumers, increase marketplace transparency, and end unfair business practices through impactful rulemakings and enforcement actions.

Letter to the Regulators: Comment to Treasury FinCEN Supporting Greater Anti-Money Laundering Screening for Registered Investment Advisers, Exempt Reporting Advisers, and Family Offices

Americans for Financial Reform Education Fund wrote a comment supporting the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposals to require additional anti-money laundering and countering of financial terrorism (CFT) requirements for Registered Investment Advisers (RIA). We also encourage FinCEN to jointly propose rulemaking with the Securities and Exchange Commission (SEC) to require the collection of beneficial ownership as well as the creation of a Customer Identification Program (CIP). 

SEC Building

Letter to the Regulators: Letter to the SEC on Finalizing the ESG Funds Disclosures Rule to Protect Investors from Greenwashing and Other Misleading Claims

AFREF and 18 additional signatories wrote to the SEC in support of bringing much-needed disclosures to the vast market of ESG-designated products and services. The letter urges the SEC to finalize the rule titled “Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices” as soon as possible and recommends changes to the way the proposed rule addresses disclosure of metrics by ESG-Focused Funds. These changes would improve the rule by generating disclosures that better reflect ESG-Focused Funds’ varied strategies and priority metrics while alleviating concerns expressed by some commenters.

In The News: How Should Federal Regulators Respond to the Capital One-Discover Deal (American Banker)

Alexa Philo and Patrick Woodall of Americans for Financial Reform: “Picture a new megabank with all the advantages and dangers of a too-big-to-fail institution. Now imagine it had the market power to bully merchants through its ownership of a payment network for debit and credit cards. Finally, throw in a track record of gouging its own customers. That’s exactly what we will have if Capital One succeeds in taking over Discover Financial Services.”

Letters to the Regulators: Letter Urging End to Overpayments to Insurance Companies and Financial Institutions

AFR joins a sign-on letter urging the Biden Administration to end billions of dollars in overpayments to insurance companies and financial institutions. These wasteful overpayments are causing significant challenges for Medicare’s financial sustainability. The fixes that CMS can and should undertake will help level the playing field between traditional Medicare and Medicare Advantage, promote health equity and bring down Part B premiums for everyone with Medicare.

News Release: Changes to Disclosures Will Increase Visibility in some Private Fund Activities

Washington, D.C. – The Securities and Exchange Commission (SEC) and the Commodities Futures Trading Commission’s (CFTC) expansions to the information collected by private funds over Form PF and Form CPO will provide both the agencies and the Financial Stability Oversight Council (FSOC) with greater visibility and early warning signs into portions of the $21 trillion private fund industry.