Category Archives: Letters to Regulators

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.

Letters to the Regulators: Letter in Support of Revisions to OMB Guidance for Grants and Agreements

The Americans for Financial Reform Education Fund (AFREF), the Institute for Policy Studies, Jobs to Move America, Communications Workers of America, United for Respect, and Take on Wall Street wrote a comment letter to the Office of Management and Budget (OMB) to recommend it be made explicit – in guidance accompanying the final rule – that local and state officials may take responsible action to consider stock buyback expenditures, exorbitant CEO pay, and private equity-driven leveraged buyouts and drastic cost-cutting when awarding federal funds.

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.