AFR commented on a set of banking agency proposals for implementing the initial Basel III rules for U.S. banks. These rules cover the definition of capital, base levels of capital for all banks, risk weighting, and exposure measurement. Upcoming rules will address capital charges for
In an Oct. 9th letter to the CFPB, AFR criticized the bureau’s proposed rule for mortgage servicers, especially a provision allowing servicers to take a “dual-track” approach – considering a loan modification and pursuing foreclosure at the same time. The letter, co-signed by the NAACP,
AFR joined more than 35 organizations in signing onto a comment letter regarding the CFPB’s servicing standards proposal.
AFR submitted a comment letter to the CFPB regarding their servicing standards proposal.
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 submitted a comment letter opposing the CFTC’s overly broad exemption for derivatives traded between bank affiliates.
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 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 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 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.