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.
Category Archives: Letters to Regulators
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.
Comment Letter on Basel III Regulatory Capital Rules
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
AFR in the News: Consumer Groups Ask CFPB to Scrap Mortgage Rules as Inadequate
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,
Public Interest Organizations Submit Comment Letter Regarding CFPB’s Servicing Standards Proposal
AFR joined more than 35 organizations in signing onto a comment letter regarding the CFPB’s servicing standards proposal.
AFR Comment Letter on CFPB Servicing Standards Proposal
AFR submitted a comment letter to the CFPB regarding their servicing standards proposal.
AFR and AFL-CIO Oppose Anti-Investor JOBS Act General Solicitation Rule
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 Comment Letter: Derivatives Exemption Too Broad
AFR submitted a comment letter opposing the CFTC’s overly broad exemption for derivatives traded between bank affiliates.
AFR Comment Letter to CFPB on High Cost Mortgage Loans
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.