AFR Letter: Resolution Plans Fall Far Short
More specificity and disclosure are needed in the big banks’ “living wills.”
Category Archives: Letters to Regulators
AFR Statement on SEC Approval of Copper ETFs
As speculative interest increases, this vital industrial commodity will be withdrawn from the market, and prices for real-economy businesses and consumers will increase.
Comments on Wells Fargo CRA Exam: Servicing and Mortgage Problems
AFR joins 10 housing groups in asking OCC to downgrade Wells Fargo for its harmful mortgage and loan servicing practices.
Comments on Wells Fargo CRA Exam: Payday Lending Problems
OCC is asked to downgrade the bank over its Direct Deposit Advance loan product.
Comment Letter on Margin Requirements for Uncleared Swaps
AFR wrote to prudential regulators concerning margin requirements for uncleared swaps, calling for the strengths in the current proposal to be maintained and also for the proposal to be improved in a number of areas.
Wide Range of Groups Oppose FHFA G-fee Proposal
FHFA’s proposal to charge more in states with consumer protections has elicited letters of strong opposition from housing and consumer advocates, members of Congress, legal and policy experts, Attorneys General, state legislators, and others.
AFR Letter on FHFA Guarantee Fees
In a joint letter, AFR and allied organizations challenge FHFA plan to charge higher guarantee fees in states with strong consumer protection laws.
AFR Calls for Implementation of a Strong Volcker Rule
AFR urges regulators to strengthen their original proposal and not to be swayed by exaggerated industry concerns about market liquidity.
Comment Letter on Stable Value Contracts
In a joint letter, AFR urges the SEC and CFTC not to exempt this common type of financial guarantee, which closely resembles a swap, from new derivatives rules.
Comment Letter on S.E.C. Rules Change Involving Exchange Traded Fund (ETF) Linked to Copper
In an Oct. 23 letter, AFR urged the Securities and Exchange Commission not to to approve the organization and marketing of a commodity Exchange Traded Fund based on the storage of physical copper. Allowing speculators to hoard this vital industrial metal would damage the economy and set a dangerous precedent, the letter warned.