Category Archives: Letters to Regulators

Letters to the Regulators: AFR Submits Filing in Opposition to Capital One Financial Corporation’s Acquisition of Discover Financial Services

AFREF wrote a letter in opposition to the proposed Capital One Financial Corporation acquisition of Discover Financial Services, which would substantially erode competition and disadvantage consumers and merchants. The transaction would create the nation’s biggest credit card lender, one of the biggest banks, and a powerful vertically integrated payments network combined with a branch bank and credit card issuer.

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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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Letters to Regulators: IOSCO Should Explicitly Acknowledge That Environmental and Social Integrity Are Critical Components of the Market Integrity of Carbon Credits

Americans for Financial Reform Education Fund (AFREF) submitted a comment letter on The Board of the International Organization of Securities Commissions (IOSCO)’s Consultation Report outlining a proposed set of Good Practices to promote the integrity and orderly functioning of Voluntary Carbon Markets (VCMs).  IOSCO has

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Letters to the Regulators: Letter in Support of Developing a Financial Inclusion Strategy

Americans for Financial Reform Education Fund (AFREF) sent a letter to the Treasury Department outlining principles, scope, and direction for the department’s development of a financial inclusion strategy.  Developing a financial inclusion strategy is long-overdue and a necessary step to understand and begin to address the contributions of inequitable access to financial products and services for disadvantaged communities to the persistent racial economic inequality in the United States.

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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.

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