Category Archives: Letters and Statements

SEC Building

Letters to Regulators: SEC Climate Disclosure – New Developments February 2023

We are writing on behalf of Public Citizen, Americans for Financial Reform Education Fund, and Sierra Club to supplement the information provided in previous comments we submitted. The purpose of this letter is to highlight a number of recent developments that further strengthen the rationale for the proposed rule.

As explained in our attached summary of developments related to climate-related financial risk, dramatic changes ushered in by the Inflation Reduction Act, the Russian invasion of Ukraine, and global market trends more generally, are accelerating a rapid transformation in the investment landscape.

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a dollar bill on top of a pile of money with scrabble pieces spelling out "tax" on top

News Release: Chevron Mega-Stock Buybacks Program Shows Need for Tougher Rules

Washington, D.C. – The announcement that Chevron will spend $75 billion on stock buybacks underscores the urgency of reinforcing a measure Congress created last year to penalize companies that engage in a financial practice that amplifies rampant wealth inequality, and in this case boosts the bottom line of a climate-harming industry.

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News Release: OCC Should Follow CFPB Lead in Drawing Tough Line on Repeat Offenders

The nation’s big-bank regulator, the Office of the Comptroller of the Currency, should help broaden and extend a crackdown on financial institutions that repeatedly violate the law – notably Wells Fargo – with all the tools at its disposal. Comptroller Michael Hsu is speaking on the problem of “too big to manage” today. The speech comes about a month after the Consumer Financial Protection Bureau ordered Wells to pay $3.7 billion over widespread mismanagement of auto loans, mortgages, and deposit accounts, and promised to work with other federal regulators to find durable solutions to its constant violations of the law.

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Amicus Brief: Uphold the President’s Cancellation of Student Debt

AFR joined partners as amici in urging the United State Supreme Court in upholding the President’s plan to cancel up to $20,000 in student loan debt for borrowers. This cancellation has the power to shift the racial wealth gap, free borrowers of the weight of student loan debt and potentially plant BIPOC communities on even ground with their white counterparts.

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In The News: Advocacy Group Calls for Checks on Private-Equity Debt (The Wall Street Journal)

Andrew Park, senior policy analyst for hedge funds and private equity at Americans for Financial Reform and the author of the report, estimates the volume of leveraged loans and high-yield debt outstanding has roughly doubled since 2008, while the volume of direct-lending debt has increased from virtually zero to an estimate of more than $1 trillion.  “The fact is that there is no good way to understand how indebted companies actually are,” [Mr. Park] said. “We have guesses and estimates based on the data out there, but there is no standardized way to look at it.”

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News Release: Subprime Corporate Debt, Hitting $5 Trillion, Brings Defaults, Slower Growth

The explosion of low-quality lending has brought debt loads in corporate America to record highs, a development that is likely to bring, in the coming years, a wave of defaults, slower growth, future job losses, and potential instability stemming from the utter opacity of this business. Despite the exponential growth in subprime corporate debt, our laws and regulations have not kept up, leaving policymakers and regulators in the dark as to the exact size of this market and where various risks may exist that could affect other financial institutions, companies, and their workers.

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News Release: Banks Should Heed Fed Warning on Crypto Asset Risks

Washington, D.C. — The Federal Reserve and other banking regulators made the right call Tuesday by issuing a warning regarding the risks that crypto-assets pose to banking organizations. There is widespread volatility, fraud risk, legal uncertainties, unfair and deceptive practices, run and contagion risks, high levels of concentration and interconnections between firms, and poor risk management and governance found throughout the industry – all of which spells danger for investors and consumers alike. 

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