Public Interest Organizations Submit Comment Letter Regarding CFPB’s Servicing Standards Proposal
AFR joined more than 35 organizations in signing onto a comment letter regarding the CFPB’s servicing standards proposal.
Category Archives: Letters to Regulators
AFR Comment Letter on CFPB Servicing Standards Proposal
AFR submitted a comment letter to the CFPB regarding their servicing standards proposal.
AFR and AFL-CIO Oppose Anti-Investor JOBS Act General Solicitation Rule
In a joint comment letter submitted today to the Securities and Exchange Commission, AFR and AFL-CIO expressed strong opposition to the agency’s proposed rule lifting the ban on general solicitation and advertising in private offerings. The groups called on the SEC to withdraw the rule proposal and issue a new rule incorporating reasonable safeguards to protect investors and promote market integrity.
AFR Comment Letter: Derivatives Exemption Too Broad
AFR submitted a comment letter opposing the CFTC’s overly broad exemption for derivatives traded between bank affiliates.
AFR Comment Letter to CFPB on High Cost Mortgage Loans
AFR submitted a comment letter to the CFPB on their proposed rules implementing Dodd-Frank changes regarding high cost mortgage loans. The letter argues against changing triggers for high cost loans for smaller loans which the statute allows but does not require, and argues that the proposal should be strengthened in various ways, including by making sure that borrowers in revolving lines of credit get the same protections as those in closed end mortgages.
AFR Comment Letter: Do Not Interfere With State and Local Use of Eminent Domain to Aid Homeowners
AFR wrote to the Federal Housing Finance Administration asking them not to interfere in state and local use of eminent domain to aid homeowners in restructuring underwater mortgages
AFR Comment Letter: Designation of Swaps that Must be Cleared
AFR submitted a comment letter to the CFTC on the clearing mandate. This is the CFTC’s initial proposal for what derivatives will have to be cleared, and the CFTC has the ability to designate more swaps for clearing, which AFR recommends in the letter.
AFR Comment Letter: CFTC Derivatives Rules Must Apply to Foreign Affiliates
AFR submitted a comment letter to the CFTC regarding a rule that will determine whether the CFTC can regulate derivatives trading by foreign affiliates of US banks and corporations. Since derivatives trades move easily around the world and between affiliates and the parent company, it is important that US regulators be able to apply Dodd-Frank to such foreign trades. Our letter urged the CFTC not to let financial institutions escape derivatives rules by funneling transactions through their foreign affiliates.
Sign on Letter: JOBS Act Rulemaking Raises Complex Concerns
The JOBS Act rulemaking on the SEC’s schedule Aug. 22 raises a variety of complex issues that demand a full and transparent rulemaking process. The rushed approach to rulemaking reportedly contemplated by the agency would not allow for full consideration of these issues, and would therefore put investors at risk.
AFR Comment Letter: Oppose Delay of International Derivatives Rules
AFR submitted a comment letter to the CFTC opposing the delay of key international derivatives rules. At a minimum, safe guards should be maintained if the delay is granted.