Category Archives: Letters to Regulators

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Letter to Regulators: AFR Submits Comment on the SEC’s Proposed Title VII “Bad Actor” Waiver Process

“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. “

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Letter to Regulators: AFR Encourages Treasury to Monitor Peer to Peer Lending

“Americans for Financial Reform (AFR) is pleased to submit these responses to the RFI issued by the Department of the Treasury. The extraordinary diversity of on-line lending models and the rapid growth of the sector mean that continued monitoring will be necessary and the sector will likely fall into the purview of multiple regulators. We encourage the Treasury Department to remain active in determining the appropriate regulatory models, and we will further examine the responses to this RFI with interest to evaluate what types of regulation seem appropriate.”

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Letter to Regulators: AFR Supports CFTC Proposal to Toughen Cross Border Margin Rules; Urges Broader Reexamination of Cross Border Regulation

“In numerous previous comments, AFR has raised serious concerns about the Commission rules and guidance that exempt foreign subsidiaries of U.S. banks, or U.S. subsidiaries of foreign entities that are highly active on Wall Street, from a wide range of Dodd-Frank derivatives rules. Given the global character of the derivatives market, we believe that such cross-border exemptions create the possibility for large-scale evasion of U.S. rules.”

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Letter to Regulators: AFR Joins 31 Organizations in Cautioning Against Potential Loopholes in CFPB’s Prepaid Card Proposal

“The undersigned consumer and civil rights organizations write to urge you to issue final prepaid card rules that prevent payday lenders and other predatory lenders from attaching dangerous credit features to the cards. We appreciate the strong elements of the proposed rules, which recognize that overdraft services are a form of credit and that credit accessed through cards must have the robust protections of the Credit CARD Act. While the proposed rules will stop some abuses, we are concerned that loopholes in the proposal can be exploited.”

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Letters to Regulators: Organizations Weigh in on Treasury’s Peer to Peer Lending

“…responses to the RFI issued by the Department of the Treasury. The extraordinary diversity of on-line lending models and the rapid growth of the sector mean that continued monitoring will be necessary and the sector will likely fall into the purview of multiple regulators. We encourage the Treasury Department to remain active in determining the appropriate regulatory models, and we will further examine the responses to this RFI with interest to evaluate what types of regulation seem appropriate.”

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Letter to Regulators: AFR Calls on Department of Labor to Protect Retirement Investors

“This is a huge problem – one that, over time, can easily add up to a difference of tens or even hundreds of thousands of dollars in retirement savings. Under the current rules, some of the financial professionals offering retirement investment advice are legally bound to look out for the best interests of their clients; but other professionals, while perceived as having such a duty and clearly benefiting from the perception, are free to put their own interests first, even if that means saddling their clients with needlessly high fees or inappropriate risks.”