Category Archives: Letters to Regulators

Letters to the Regulators: Letters to the Financial Stability Oversight Council in Support of Increased Supervision of Nonbank Companies and Revising the Analytic Framework for Assessing Financial Stability Risk

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.

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.