Americans for Financial Reform

Government Category: Advocacy Documents

Letter to Regulators: AFR Ed Fund Opposes Elimination of Derivatives Risk Controls

We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.

Letter to Congress: AFR endorses package of student borrower protection bills

Americans for Financial Reform wrote to Congress to express our support for The Student Borrower Protection Act, The Fair Student Loan Debt Collection Practices Act, and The Private Loan Disability Discharge Act. The student loan protections, transparency measures, and servicing reforms included in these bills are urgently needed so that borrowers are treated more fairly, basic standards are clearer, and borrowers facing challenging circumstances have every opportunity to succeed.