Category Archives: Letters to Regulators

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AFR Letter: Mandatory Margin Requirements Needed for Uncleared Swaps

“Mandatory margin requires participants in the swaps market to take full account of the risks of their derivatives transactions and provide some level of advance provisioning for such risks. The availability of properly segregated margin is clearly of enormous value in case of the default of a swaps counterparty.”

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AFR Letter: CFTC and SEC Must Act Against Derivatives “De-Guaranteeing” Ploy

“On behalf of Americans for Financial Reform (AFR), we write today to ask you to ensure appropriate regulatory oversight of derivatives transactions conducted through foreign subsidiaries of multinational Wall Street banks. In particular, we urge you to prevent the inappropriate classification of such derivatives as ‘non-guaranteed’ by the parent company, a classification which could exempt them from numerous critical derivatives regulations.”

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AFR Joins More than 200 Other Groups in Urging FHFA Director Mel Watt to Reverse Fannie-Freddie Policy on Principal Reduction

Mel Watt is being urged again to end the policy of prohibiting mortgage modifications that reduce the balance of principal. In a joint letter delivered today, more than 200 housing, community, labor, civil rights and consumer groups call on Watt to reverse the Federal Housing Finance Agency’s longstanding ban on principal reduction – a policy put in place by his predecessor.

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AFR and More Than 50 U.S. and International Groups Warn that TTIP Could Undermine Financial Reform

In a letter to U.S. and EU trade negotiators and finance ministers, more than 50 civil society groups on both sides of the Atlantic have come together to warn that the Transatlantic Trade and Investment Partnership (TTIP) currently under discussion could undermine new financial regulations and potentially create significant risks to the global financial system, as well as to investors and consumers.

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AFR Calls for Restrictions on Wall Street Executive Pay and Bonuses

AFR submitted a comment letter to federal regulators urging that they impose strong restrictions on Wall Street executive pay and bonuses to ensure that they do not create incentives to take inappropriate short-term risks. This should be made a critical priority, given the role of pay in creating the incentives that led to the 2008 financial crisis.

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AFR Comment Letter to CFPB on Request for Input on Mobile Financial Services

AFR offered comments to the Consumer Financial Protection Bureau in response to their Request for Input on how consumers are using mobile financial services to access products and services, and manage finances. While mobile technology can enhance access to safer and more affordable technology for consumers, benefits will only be seen if technological systems are safe, fair, and honest. Regulators can help consumers—as well as those in industry—by establishing strong minimum standards.