Category Archives: Letters to Regulators

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Letter to Regulators: AFR Provides Comments to Regulators on Controlling Wall Street bonuses

“Americans for Financial Reform (“AFR”) appreciates this opportunity to comment on the above referenced Proposed Notice of Proposed Rulemaking (the “Proposal”) issued by the Federal Reserve, FDIC, FHFA, NCUA, OCC, and SEC (the “Agencies”)… Section 956 is a particularly significant and vital element of the Dodd-Frank Act. There is widespread agreement among students of the 2008 financial crisis that the design of bonus pay was a central contributor to the crisis. “

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Letter to Regulators: AFR Joins 32 Organizations Express Concern over CEO Bonus Pay Loophole

“We appreciate the opportunity to comment on the proposed rule regarding incentive compensation in the financial industry. This proposal is a significant improvement over the 2011 version… However, we remain deeply concerned that loopholes in the regulation will allow a reckless Wall Street bonus culture to continue, putting taxpayers and the broader economy at risk.”

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Letter to Regulators: AFR Comments on Consultative Document that would Change Derivatives Risk Exposure

“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the above mentioned Consultative Document. Among other issues, this Consultative Document proposes to change the measurement of derivatives risk exposures for leverage ratio purposes by replacing the Current Exposure Method (CEM) used today with the Standardized Approach to Counterparty Credit Risk (SA-CCR). The document implies that the SA-CCR has a more realistic approach to risk measurement, while the CEM is more conservative.”

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Letter to Regulators: AFR, 21 organizations call on FHFA to include language preference on mortgage applications

“We are writing in response to the letter you received recently from a number of industry trade groups opposing the inclusion of preferred language data fields in the redesigned Uniform Residential Loan Application (URLA)… The URLA redesign presents a unique and unprecedented opportunity to take an important first step towards addressing equitable access to the mortgage market for LEP consumers and we strongly urge you to include preferred language data fields.”

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Letter to Regulators: AFR Comments on the Fed’s Proposed Rule on Credit Limits

“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the Federal Reserve Board’s (the “Board”) Notice of Proposed Rulemaking (“Proposed Rule” or “Proposal”) on the above-mentioned rule. Section 165 of the Dodd-Frank Act mandates the imposition of single counterparty credit limits (SCCL), and significantly expands the range of exposures that are captured under such limits. This Proposed Rule is a re-proposal of the Board’s original 2011 proposal regarding credit exposure limits, and makes a number of changes to the original proposal. ”

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Letter to Regulator: AFR Comments to Basel Committee On Bank Transparency

“Given the complexity of the regulations now applying to global banks, a comprehensive new set of disclosures is absolutely necessary in order to help both investors and civil society organizations such as ourselves understand bank activities. A clear and consistent set of public disclosures should also be helpful for financial regulators, who under the U.S. system do not always have access to bank supervisory data that may be relevant to the markets they oversee.”

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Letter to Regulators: AFR Supports Strong Consumer Protections in FCC Robocalls Rule

Because of the significant harm caused by these robocalls from debt collectors, AFR is very supportive of the consumer protections proposed by the FCC in this rulemaking. The Commission has also proposed two other very important provisions that we think are good, but that need to be improved — including narrowing its limit of three allowable calls per month per loan to three calls per month per servicer.