Category Archives: Letters and Statements

Blog: Opaque Private Credit Industry Threatens Heavy Debt Burdens, Systemic Risk

Problems are brewing in a scheme that is bigger than the Australian economy and almost completely without federal oversight. It is called private credit — large scale lending, but not by banks — and has surged from less than $300 billion in loans in 2013 to over $2.1 trillion globally today. This unregulated market has become yet another tool for the private equity industry to pursue leveraged buyouts and leaves target companies on the hook to repay the new mountains of debt. If this large pool of unregulated loans go sour, the distress could spread into the broader financial system, including traditional banks, and pose systemic risk to the financial system.

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Blog: Powell Should Recuse Himself from Basel Endgame Process

Federal Reserve Board Chairman Powell, you should recuse yourself from the consideration of the Basel III Endgame regulatory capital rule to preserve the integrity of Federal Reserve regulatory decision-making and avoid the appearance of impropriety that would undermine public perception of the central bank’s independence and impartiality. Meeting with big bank CEOs in secret creates the appearance that powerful regulated entities cannot merely influence rulemaking during the public notice and comment period and through their policy arguments, but that they can meet off the record and set regulatory red lines which federal authorities will not cross.  

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New Poll Shows Voters Across Party Lines Want CFPB Action to Curb Junk Fees, Tame Wall Street

As the focus on the American voter intensifies with the coming election, a new poll released today shows voters across the political spectrum overwhelmingly support the mission of the Consumer Financial Protection Bureau (CFPB), financial regulation generally, and a variety of specific CFPB actions, including efforts to limit credit card late fees, reduce overdraft charges, and prohibit medical debt from appearing on credit reports.

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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.

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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). 

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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.

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