We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.
We are deeply concerned that the Investment Company Institute (ICI) Letter lays out a set of changes to the Proposed Rule which wold effectively negate the derivatives exposure limits in the rule and render them useless as a tool for controlling speculative leverage at registered funds, as is required by the 1940 Act. …This change would not simply modify the relative weighting of derivatives exposures, but would result in a massive increase in the absolute limit on derivatives risk exposure.
AFR joins 19 other organizations to express our opposition to H.R. 6392, the “Systemic Risk Designation Improvement Act of 2015.” This legislation increases the likelihood of big bank failures that could put at risk the economic security of millions of families.
“Far from improving systemic risk regulation, this legislation increases the likelihood of big bank failures that could put at risk the economic security of millions of families. It puts unprecedented new constraints on the ability of the Federal Reserve to provide basic oversight of large bank holding companies, including provisions that grant an unaccountable council of international regulators statutory powers over U.S. regulatory decisions. It would also politicize bank regulatory decisions, granting the Treasury Secretary of the incoming Administration new powers to pick and choose which big banks must follow basic safety rules.”
“The budget is not the place to try to force through provisions that are dangerous to economic stability or to families economic security, would not pass alone, or that the President would likely veto. We strongly urge Members of Congress to oppose any flawed funding proposals that undermine the CFPB, the Dodd-Frank Act, the DOL’s conflict-of-interest rule, or other financial reform and accountability legislation or regulations.”
AFR joined with the AFL-CIO in calling on the Securities and Exchange Commission to revise its proposed rule so that “any changes to the Commission’s disclosure rules do not narrow the scope of information that is provided to investors.”