Americans for Financial Reform

Government Category: Advocacy Documents

Letters to the Regulators: Letter to the SEC Supporting the Prohibition of Conflicts of Interests in Securitization

Americans for Financial Reform Education Fund submitted a comment to the Securities and Exchange Commission (SEC) supporting its proposal to prohibit conflicts of interest in securitizations. Such conflicts were at the heart of the Great Financial Crisis of 2008 leading to trillions of dollars in losses across the financial system and irreparable harm to millions of homeowners. Now, with the growth in securitizations such as those backed by commercial real estate and other assets, the SEC’s proposals can ensure that similar practices do not happen again at the harm of investors and others.

Letters to Regulators: Comment on OIRA Cost Benefit Analysis Guidance

AFREF submitted comments to the Office of Information and Regulatory Affairs on its proposal to modernize the regulatory process to better account for racial and economic inequality, climate change, and other factors within economic analysis; and improve transparency and empower and benefit members of marginalized communities through the regulatory process.

Letters to Congress: Letter Opposing H.R. 3556 “Increasing Financial Regulatory Accountability and Transparency Act”

AFR sent a letter opposing H.R. 3556 “Increasing Financial Regulatory Accountability and Transparency Act,” a bill supposedly to make the Fed more transparent, which will instead hamstring the Financial Stability Oversight Council’s (“FSOC”) ability to effectively monitor risk in the financial system. This bill would subject the FSOC’s designation authority to Congressional review, which would allow any firm the FSOC designates as systemically important to lobby Congress to rescind the FSOC’s designation. This would render the FSOC designation authority under the Dodd-Frank Act futile and unnecessarily politicize the agency’s efforts to monitor companies that pose an outsized risk to our financial system. This bill comes at the heels of the FSOC’s announcement to reinvigorate its designation process, a welcome step in preventing the next financial crisis.

Letters to Congress: Letter in Opposition to HR 3564

AFR submitted this letter in opposition to H.R. 3564, which would make mortgages more expensive for many middle-class American families. H.R. 3564 would rescind the FHFA’s more equitable mortgage pricing framework and instead require the FHFA to increase fees for many first-time home buyers and those who do not have a 20% down payment.