View or download a PDF of the letters here: Fed, FDIC, OCC Long-Term Debt Requirements Fed, FDIC Guidance for Resolution Plan Submissions FDIC, Resolution Plans for Insured Depository Institutions AFREF submitted comments supporting proposals from the Federal Reserve, the Federal Deposit Insurance Corporation, and the
The Americans for Financial Reform Education Fund (AFREF), the Institute for Policy Studies, Jobs to Move America, Communications Workers of America, United for Respect, and Take on Wall Street wrote a comment letter to the Office of Management and Budget (OMB) to recommend it be made explicit – in guidance accompanying the final rule – that local and state officials may take responsible action to consider stock buyback expenditures, exorbitant CEO pay, and private equity-driven leveraged buyouts and drastic cost-cutting when awarding federal funds.
Americans for Financial Reform Education Fund submitted a comment letter to the Office of Management and Budget (OMB) for its approval, without delay, of the Department of the Treasury’s Federal Insurance Office (FIO) final proposed “Climate-Related Financial Risk Data Collection for U.S. Homeowners Multi-Peril Underwriting
Americans for Financial Reform Education Fund led and submitted a comment letter, to the NCUA on the agency’s draft 2024-2025 budget. The letter was endorsed by Green America, the National Coalition for Asian Pacific American Community Development, the National Fair Housing Alliance, New York Communities
Americans for Financial Reform Education Fund submitted a comment letter to the Financial Accounting Standards Board (FASB) in support of its proposal to require public companies to disaggregate certain costs from expense captions, with a focus on the disaggregation of employee compensation costs. AFREF made a series of recommendations to improve these disclosures, including recommendations to include workers beyond employees in the disclosures.
AFREF submitted a comment supporting the Federal Trade Commission’s proposed rule to require complex companies including private equity firms to disclose more information about their holdings and business lines when pursuing mergers and acquisitions.
AFREF and the National Housing Law Project submitted a comment to the FHFA in support of their proposed revisions to the Suspended Counterparty Program.
Americans for Financial Reform Education Fund sent a letter commending the Federal Trade Commission and Department of Justice for developing a robust, accessible update to the merger guidelines
AFREF submitted comment letters to the Financial Stability Oversight Council (FSOC) on two proposals that would strengthen its toolbox for addressing threats to financial stability, including those related to climate change, and make it easier to designate nonbank companies like asset managers and insurance companies as systemically important institutions that need enhanced regulation by the Federal Reserve Board.
The letters detail how threats to financial stability from nonbank financial institutions are growing, and it encourages FSOC to quickly strengthen and finalize its proposals to be able to respond effectively and proactively to emerging risks. Many nonbank financial institutions already face heightened stress from large climate-related shocks, including several major insurers’ recent decisions to withdraw coverage from many states and zip codes. Insurance companies, asset managers, private equity firms, and other nonbank financial institutions are also creating significant risks to the financial system through their insured or financed emissions — risks that are often forced upon other financial institutions and consumers who will struggle to manage them.
View or download a PDF of the letter here Americans for Financial Reform Education Fund joined the Homes Guarantee Campaign and over 300 national, state, and local organizations to call on the Federal Housing Finance Agency to require tenant protections in order to receive federal