Category Archives: Letters and Statements

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. 

Letters to the Regulators: Letter in Opposition to the CFTC’s Proposed Rulemaking and its Dangerous Precedent

Americans for Financial Reform Education Fund and Consumer Federation of America, Food & Water Watch, Institute for Agriculture and Trade Policy, and Public Citizen sent a letter sharing their grave concerns with the justification and potentially calamitous precedent contained in the Commodity Futures Trading Commission’s (CFTC’s) proposed rulemaking for the Investment of Customer Funds by Futures Commission Merchants and Derivatives Clearing Organizations. This proposal would expand the list of permitted investments for customer funds to include foreign debt which could put customers at undue financial risk — avoiding such risk was the rationale for prohibiting these transactions in 2011 after the MF Global meltdown.

Letter to Regulators: Strong Basel Capital Standards Support Growth

The bank lobby is spending vast lobbying dollars to cloak themselves in the mantle of preserving access to credit. But the truth that the banks avoid debating is that the overwhelming impact of higher bank capital is – by design – to restrict how risky and how big the more speculative aspects of their business, notably their trading and investment bank operations can grow.