AFR Urges Increased Price Competition and Transparency for SEFs
AFR sent a letter to the CFTC Commissioners in support of robust price competition and transparency requirements for Swaps Execution Facilities (SEFs).
Category Archives: Letters to Regulators
AFR Comment Letter Calls for Inclusion of YSP’s in Calculating Points & Fees Thresholds
AFR submitted a comment letter to the CFPB calling for yield spread premiums to be included in the calculation of points-and-fees thresholds. This inclusion is very important to carrying out the Dodd-Frank Act directive that prohibits steering borrowers to more expensive loans.
AFR Letter on Leverage Rules for Swaps Dealers and Broker-Dealers
SEC faulted on proposed capital, margin, and segregation requirements for Security-Based Swap Dealers (“SBSDs”), and capital requirements for Broker Dealers.
AFR Urges Increased Oversight of Money Market Mutual Funds
AFR submitted a comment letter to the Financial Stability Oversight Council urging an increase of oversight of money market mutual funds to address the systemic risk not fully addressed by current oversight rules.
AFR Calls for Increased Consumer Protections in CFPB’s Trial Disclosures Proposal
AFR submitted a comment letter to the CFPB arguing for the need of rigorous consumer protections attached to any corporate field testing of new disclosure forms.
AFR Letter: Resolution Plans Fall Far Short
More specificity and disclosure are needed in the big banks’ “living wills.”
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As speculative interest increases, this vital industrial commodity will be withdrawn from the market, and prices for real-economy businesses and consumers will increase.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.