These comments responded to the request for comments on the proposed interagency policy statement that established joint standards for assessing the diversity policies and practices of entities regulated by the agencies. AFR found that while the creation of the OMWIs in the Dodd-Frank Act was incredibly important, the joint standards released by six of the federal agencies fell unfortunately short on specifics. In particular, the standards do not provide detail or uniformity, and are additionally lacking in accountability measures to ensure that the goals of increasing worker and supplier diversity are met.
AFR commented on the CFTC’s proposal to establish position limits to limit speculation that increases prices and volatility in markets for agricultural and energy commodities. AFR urged the CFTC to strengthen the rules to be more effective in preventing excessive speculation.
More than 75 organizations joined AFR in sending a letter to members of Congress urging them to reject HR 3193. This legislation would weaken the Consumer Bureau, prevent it from doing its job and instead serve the interests of the worst elements of the financial industry.
AFR submitted a comment letter to the banking regulators concerning their proposed rule requiring banks to hold liquidity reserves (extra funds to meet payment obligations in a stressed situation.)
In a letter to Congress, AFR urges members not to let potential international trade and investment agreements, such as the Trans-Pacific Partnership (TPP) or the Transatlantic Trade and Investment Partnership (TTIP), undermine hard-fought gains in financial reform, and not to compromise U.S. sovereignty in ways that would limit our ability to take further steps to regulate the financial sector.
“[W]e are troubled by the narrow scope of the Release and some of the assumptions underlying it. AFR believes that the Commission needs to consider the broader costs and benefits to the public of permitting ever-increasing speed and ubiquity of automated trading technologies. We believe that such an analysis would support stronger limitations on automated trading than appear to be contemplated…”
