Category Archives: Letters to Regulators

Letters to the Regulators: Letter to PCAOB Supporting Proposed Audit Standards to Report Noncompliance with Laws and Regulations, Including Climate Regulations

AFREF joined Public Citizen in a comment urging PCAOB to strengthen and swiftly finalize its proposed updated audit standards around reporting noncompliance with laws and regulations and identifying risks of material misstatement in financial statements. Climate-related accounting fraud is on the rise, and many companies are misrepresenting their financial position by underestimating their asset retirement obligations and environmental liabilities, and failing to substantiate public climate commitments in their financial statements and SEC filings. 

The proposed regulatory updates from PCAOB would strengthen auditors’ responsibilities to identify and report these types of misstatements and fraud and provide a significant benefit to investors by catching costly noncompliance issues early before they harm financial performance, and to the public by deterring corporate law-breaking and noncompliance.

Letters to Regulators: Letter to Treasury, OCC, FRB and FDIC on the Need to Fight Bank Consolidation

The President has made it clear: it’s time to fight consolidation, not facilitate it. In reviewing lessons learned from this most recent banking crisis to better prevent the next one, the regulators must be full-throated and clear in their affirmation that robust regulation and competition, not consolidation, will lead to a healthier, safer, and more vibrant financial system. Banks must exist to serve the needs of the American people, not the other way around – and it is regulators’ critical task to ensure so. 

Letters to the Regulators: Letter to the SEC Supporting the Prohibition of Conflicts of Interests in Securitization

Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission (SEC) supporting its proposal to prohibit conflicts of interest in securitizations. Such conflicts were at the heart of the Great Financial Crisis of 2008 leading to trillions of dollars in losses across the financial system and irreparable harm to millions of homeowners. Now, with the growth in securitizations such as those backed by commercial real estate and other assets, the SEC’s proposals can ensure that similar practices do not happen again at the harm of investors and others.

lawyer signing a document Photo by Helloquence on Unsplash

Letters to Regulators: Comment on OIRA Cost Benefit Analysis Guidance

AFREF submitted comments to the Office of Information and Regulatory Affairs on its proposal to modernize the regulatory process to better account for racial and economic inequality, climate change, and other factors within economic analysis; and improve transparency and empower and benefit members of marginalized communities through the regulatory process.

Letters to Regulators: EPA Should Continue to Develop Greenhouse Gas Reduction Fund Guidance that Delivers Tangible Benefits to Low-Income and Disadvantaged Communities Across the Country

May 12, 2023 Americans for Financial Reform Education Fund (AFREF) submitted an environmental justice advocates comment letter signed by Public Citizen and WE ACT for Environmental Justice to the Environmental Protection Agency (EPA) on its Implementation Framework for the Greenhouse Gas Reduction Fund.  The Implementation