AFR Comment Letter: Derivatives Exemption Too Broad
AFR submitted a comment letter opposing the CFTC’s overly broad exemption for derivatives traded between bank affiliates.
Government Category: Advocacy Documents
Public Interest Groups Urge Opposition to HR 2827
AFR, The Leadership Conference, AFL-CIO, AFSCME, U.S. PIRG, Public Citizen, and Consumer Federation of America. While this legislation is an improvement on earlier versions of the bill, it still represents a significant weakening of taxpayer protections created by the Dodd-Frank Act to prevent fraud, abuse, and deception in Wall Street financial dealings with municipalities.
AFR Comment Letter to CFPB on High Cost Mortgage Loans
AFR submitted a comment letter to the CFPB on their proposed rules implementing Dodd-Frank changes regarding high cost mortgage loans. The letter argues against changing triggers for high cost loans for smaller loans which the statute allows but does not require, and argues that the proposal should be strengthened in various ways, including by making sure that borrowers in revolving lines of credit get the same protections as those in closed end mortgages.
AFR Comment Letter: Do Not Interfere With State and Local Use of Eminent Domain to Aid Homeowners
AFR wrote to the Federal Housing Finance Administration asking them not to interfere in state and local use of eminent domain to aid homeowners in restructuring underwater mortgages
AFR Letter: Oppose S. 3468 “The Independent Agency Regulatory Analysis Act”
AFR sent a letter of opposition to members of Congress regarding S. 3468, The Independent Agency Regulatory Analysis Act, which would give the Office of Information and Regulatory Affairs (OIRA) jurisdiction over all independent agencies in the federal government, including all of the financial regulatory agencies.
AFR Comment Letter: Designation of Swaps that Must be Cleared
AFR submitted a comment letter to the CFTC on the clearing mandate. This is the CFTC’s initial proposal for what derivatives will have to be cleared, and the CFTC has the ability to designate more swaps for clearing, which AFR recommends in the letter.