AFR Urges SEC to Include Investor Protections in JOBS Act Rulemaking
AFR submitted a letter to the SEC expressing deep concern that the rules proposed by the Commission regarding the JOBS Act fail to deliver important investor protections.
Category Archives: Letters to Regulators
AFR Calls on International Regulators to Improve Derivatives Market Transparency
AFR submitted a comment letter to the financial stability board on plans for the aggregation of global derivatives data.
AFR Comments on OMWI Proposed Standards
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 Urges Improvements in Rules to Limit Commodity Market Speculation
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 Letter to Banking Regulators on Liquidity Coverage Rule
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.)
AFR Calls on Regulators to Ban Predatory High Frequency Trading
“[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…”
AFR Urges SEC to Stand Firm on Corporate Pay-Ratio Disclosure
“[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.”
Federal Regulators Urged to Crack Down on Bank Complicity in Illegal Payday Loans
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 Urges Stronger Leverage Ratio
AFR wrote to the banking regulators to urge them to strengthen the new supplementary leverage ratio proposed for large U.S. banks.
Materials on Fiduciary Duty of Financial Advisors
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.