Letters to Regulators Archives - Americans for Financial Reform

Letters to the Regulators: Letter in Support of the Financial Accounting Standards Board’s Expense Disaggregation Proposal

Americans for Financial Reform Education Fund submitted a comment letter to the Financial Accounting Standards Board (FASB) in support of its proposal to require public companies to disaggregate certain costs from expense captions, with a focus on the disaggregation of employee compensation costs. AFREF made a series of recommendations to improve these disclosures, including recommendations to include workers beyond employees in the disclosures.

Letters to the Regulators: Letter in Support of the FTC’s Proposed Rulemaking for Premerger Notification, Reporting, and Waiting Period Requirements

AFREF submitted a comment supporting the Federal Trade Commission’s proposed rule to require complex companies including private equity firms to disclose more information about their holdings and business lines when pursuing mergers and acquisitions.

Letters to the Regulators: Letter in Support of Proposed Revisions to the Suspended Counterparty Program

AFREF and the National Housing Law Project submitted a comment to the FHFA in support of their proposed revisions to the Suspended Counterparty Program.

Letters to the Regulators: Letter in Support of Proposed Merger Guidelines

Americans for Financial Reform Education Fund sent a letter commending the Federal Trade Commission and Department of Justice for developing a robust, accessible update to the merger guidelines

Letters to the Regulators: Letters to the Financial Stability Oversight Council in Support of Increased Supervision of Nonbank Companies and Revising the Analytic Framework for Assessing Financial Stability Risk

AFREF submitted comment letters to the Financial Stability Oversight Council (FSOC) on two proposals that would strengthen its toolbox for addressing threats to financial stability, including those related to climate change, and make it easier to designate nonbank companies like asset managers and insurance companies as systemically important institutions that need enhanced regulation by the Federal Reserve Board.

The letters detail how threats to financial stability from nonbank financial institutions are growing, and it encourages FSOC to quickly strengthen and finalize its proposals to be able to respond effectively and proactively to emerging risks. Many nonbank financial institutions already face heightened stress from large climate-related shocks, including several major insurers’ recent decisions to withdraw coverage from many states and zip codes. Insurance companies, asset managers, private equity firms, and other nonbank financial institutions are also creating significant risks to the financial system through their insured or financed emissions — risks that are often forced upon other financial institutions and consumers who will struggle to manage them.

Letters to the Regulators: Letter to FHFA in Support of Tenant Protections

View or download a PDF of the letter here Americans for Financial Reform Education Fund joined the Homes Guarantee Campaign and over 300 national, state, and local organizations to call on the Federal Housing Finance Agency to require tenant protections in order to receive federal

Letters to the Regulators: Letter to PCAOB Supporting Proposed Audit Standards to Report Noncompliance with Laws and Regulations, Including Climate Regulations

AFREF joined Public Citizen in a comment urging PCAOB to strengthen and swiftly finalize its proposed updated audit standards around reporting noncompliance with laws and regulations and identifying risks of material misstatement in financial statements. Climate-related accounting fraud is on the rise, and many companies are misrepresenting their financial position by underestimating their asset retirement obligations and environmental liabilities, and failing to substantiate public climate commitments in their financial statements and SEC filings.

The proposed regulatory updates from PCAOB would strengthen auditors’ responsibilities to identify and report these types of misstatements and fraud and provide a significant benefit to investors by catching costly noncompliance issues early before they harm financial performance, and to the public by deterring corporate law-breaking and noncompliance.

Letters to Regulators: CFPB Should Finalize Residential PACE Rule and Develop Consumer Protections for Emerging Green Lending Products

Americans for Financial Reform Education Fund submitted a comment letter, endorsed by 20 partner organizations, to the Consumer Financial Protection Bureau (CFPB)’s proposed rule on residential Property Assessed Clean Energy (PACE) financing. The letter urges the CFPB to finalize the residential PACE rule swiftly to

Letters to Regulators: Comment Letter in Support of the SEC’s Proposal to Modernize Beneficial Ownership Reporting

AFREF, the AFL-CIO, Communications Workers of America, the Interfaith Center on Corporate Responsibility, and Public Citizen submitted a comment letter in support of the SEC’s proposal to modernize beneficial ownership reporting in response to a new memorandum by the Division of Economic and Risk Analysis.

Letters to Regulators: Comment Letter to FHFA on Language Access, Fair Lending Oversight, and EHF

The Language Access Task Force of Americans for Financial Reform (AFR) submits the following comments in strong support of the Federal Housing Finance Agency (FHFA)’s Notice of Proposed Rulemaking on Fair Lending Oversight and Equitable Housing Finance.