These comments responded to the request for comments on the proposed interagency policy statement that established joint standards for assessing the diversity policies and practices of entities regulated by the agencies. AFR found that while the creation of the OMWIs in the Dodd-Frank Act was incredibly important, the joint standards released by six of the federal agencies fell unfortunately short on specifics. In particular, the standards do not provide detail or uniformity, and are additionally lacking in accountability measures to ensure that the goals of increasing worker and supplier diversity are met.
AFR commented on the CFTC’s proposal to establish position limits to limit speculation that increases prices and volatility in markets for agricultural and energy commodities. AFR urged the CFTC to strengthen the rules to be more effective in preventing excessive speculation.
AFR submitted a comment letter to the banking regulators concerning their proposed rule requiring banks to hold liquidity reserves (extra funds to meet payment obligations in a stressed situation.)
“[W]e are troubled by the narrow scope of the Release and some of the assumptions underlying it. AFR believes that the Commission needs to consider the broader costs and benefits to the public of permitting ever-increasing speed and ubiquity of automated trading technologies. We believe that such an analysis would support stronger limitations on automated trading than appear to be contemplated…”
“[W]e thank you for your work in drafting an effective rule implementing section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Given that three years have passed since the enactment of the law , we urge you to move quickly to put the final rule in place.”
AFR joined the National Consumer Law Center, Consumer Federation of America, the Center for Responsible Lending, and 26 other consumer and civil rights groups call for stronger measures to stop banks and payment processors from helping internet and tribal payday lenders collect illegal payments from consumers’ bank accounts.
AFR wrote to the banking regulators to urge them to strengthen the new supplementary leverage ratio proposed for large U.S. banks.
AFR stands with many of our partner organizations in opposition to HR 2374, which would delay needed reforms that would protect middle-class savings and help to restore needed confidence in our financial markets. Here is a compilation of materials on the issue of HR 2374.
AFR supports SEC rule proposals to strengthen protections for investors in private offerings, but urges the SEC to do more to reduce the risk of fraud and misleading practices.
Overseas affiliates of U.S. banks played a major role in the final meltdown of 2008-2009, at a cost of millions of jobs and trillions of dollars. Financial institutions must not be allowed to escape oversight by “off-shoring” their riskiest deals.