AFR submitted a comment letter to the CFTC regarding a rule that will determine whether the CFTC can regulate derivatives trading by foreign affiliates of US banks and corporations. Since derivatives trades move easily around the world and between affiliates and the parent company, it is important that US regulators be able to apply Dodd-Frank to such foreign trades. Our letter urged the CFTC not to let financial institutions escape derivatives rules by funneling transactions through their foreign affiliates.
The JOBS Act rulemaking on the SEC’s schedule Aug. 22 raises a variety of complex issues that demand a full and transparent rulemaking process. The rushed approach to rulemaking reportedly contemplated by the agency would not allow for full consideration of these issues, and would therefore put investors at risk.
AFR submitted a comment letter to the CFTC opposing the delay of key international derivatives rules. At a minimum, safe guards should be maintained if the delay is granted.
AFR sent a letter to members of Congress urging them to oppose H.R. 2446. This legislation will exempt payments related to homeowner warranties (also known as home service contracts) from the Real Estate Settlement Procedure Act’s ban on kickbacks and referral fees. We believe exempting payments related to these products from the ban on kickbacks and referral fees would be harmful to consumers.
AFR and CFA sent a letter endorsing S. 3416, a piece of legislation which would enable the SEC to impose more meaningful fines on those who violate the securities laws and perpetrate fraud.
AFR sent a letter to members of Congress urging them to oppose H.R. 6139. This legislation would weaken consumer protection against financial abuses, undermine the authority of the CFPB over a huge swath of consumer financial products and services, and override state consumer protection laws through preemption.
