Category Archives: Letters to Regulators

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.

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.