“Americans for Financial Reform (“AFR”) appreciates this opportunity to comment Public Consultation on Non-Traditional Non-Insurance Activities and Products (the ‘Consultation’) by the International Association of Insurance Supervisors (the “IAIS”). We believe that improvements in insurance company regulation are necessary to address such systemic risks. “
“We commend the Commission and the Division of Swap Dealer and Intermediary Oversight staff for their work in compiling this Preliminary Report. We believe that the Commission should continue on the path laid out in the final rule and reduce the de minimis threshold to $3 billion after the $8 billion phase-in threshold terminates on December 31, 2017. We do not see sufficient evidence in the report to justify either maintaining the current level, or increasing it.”
We strongly support SEC action to improve oversight of potential liquidity issues in open-ended funds, and believe that the proposed rule should be adjusted in a number of ways to better achieve that end.
AFR is calling on financial regulators to provide the public with more transparency on the implementation of the Volcker Rule, the historic prohibition on bank proprietary trading incorporated into the Dodd-Frank Act.
“This week, the Commission faces key decisions in finalizing a crucial protection against derivatives risk, namely the rules governing mandatory provision of margin for derivatives transactions… In this letter, we wish to address one important area of these margin rules, namely requirements for inter-affiliate margin in transactions between swap dealers and affiliated entities. This issue has taken on increased prominence in recent months due to intense lobbying by major Wall Street banks to reduce or eliminate requirements for initial margin in inter-affiliate transactions. “
“We are writing on behalf of the Consumer Federation of America (CFA) and Americans for Financial Reform to express our opposition to the Financial Accounting Standards Board (FASB)’s recently proposed changes to its discussion of materiality and its guidance regarding how to assess the materiality of disclosures contained in the footnotes of financial statements… Weakening the materiality standard and increasing regulatory deference to issuer and auditor judgments has long been a goal of the preparer community. These efforts have been strongly resisted by investors and investor advocates. It is disappointing, to say the least, to see FASB put forward a proposal that is so clearly intended to advance this anti-investor, anti-transparency agenda.
“We, the undersigned organizations, are writing regarding the current open seats for Commissioners at the Commodity Futures Trading Commission (CFTC). It is vital that you nominate individuals who have both the publicly demonstrated commitment to financial reform and the financial markets expertise that is necessary to complete the implementation of crucial Dodd-Frank mandated reforms of our financial and commodity derivatives markets. “
“The undersigned organizations are writing to provide comments to the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) on the proposed regulations relating to disguised payments for services between private equity partnerships and partners under Section 707(a)(2)(A) of the Internal Revenue Code. We strongly support the proposed regulations to close the loopholes in the tax code that permit private equity firms to lower their taxes by converting management fees, typically taxed as ordinary income, into capital gains. “
“We are writing in response to recent press accounts discussing the reappointment or possible replacement of the current PCAOB Chairman James Doty. We are concerned that these reports undermine Chairman Doty and his efforts to improve the independence and quality of public company audits. We urge you to lay this speculation to rest by quickly announcing his reappointment as Chair.”
With a government shutdown narrowly averted and budget negotiations moving into a potentially volatile final stage, more than 160 national, state and local organizations are telling lawmakers and the Administration not to let the process be used to force through ideological spending riders that would block financial reform or undermine the funding or authority of the Consumer Financial Protection Bureau.