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.
“We believe that it is important that the Commission work to establish true mechanisms for accountability. One way to do that is to develop procedures that allow for public transparency into exemptions and exclusions from prohibitions triggered by statutory disqualifications… We welcome the formalized Proposed Rule of Practice 194, which creates an opportunity for enhanced clarity for both the public and the financial industry. “
“We are writing because we are concerned about the slow progress toward the implementation of Section 956(b) of the Dodd Frank Wall Street Reform and Consumer Protection Act, which prohibits large financial institutions from using compensation schemes that encourage excessive risk taking. “
“We, the undersigned organizations concerned with data privacy and consumer protection, write to express grave concerns raised by the early reports of the significant data security breach affecting T-Mobile customers and applicants whose information was stored by Experian. “