Americans for Financial Reform

Government Category: Comments & Letters to Regulators

Letter to Regulators: AFR Education Fund letter to the CFTC regarding proposed rule on swaps registration thresholds and transaction requirements to cross- border transactions

The Americans for Financial Reform Education Fund wrote a letter to the Commodity Futures Trading Commission urging them to strengthen a proposed rule that would fatally weaken the implementation of Title VII of Dodd-Frank and its application to CFTC-regulated derivatives markets. In the letter, AFR Education Fund urged the Commission to step back from course outlined

Letter to Regulators: AFREF-EFF Letter to FTC on Private Equity takeover of .ORG

“PIR LLC will have to generate substantial additional revenue to service the debt which could force PIR LLC to take advantage of its monopoly position to raise prices to unsustainable levels, impose new service charges, reduce technical upkeep that could impair web connectivity or non-profit email traffic, or pursue other business strategies that could undermine the independence of non-profits including suspending or transferring domain names, in effect a censorship-for-profit strategy that has been used by other domain registries and internet companies.”

Letter to Regulators: Assessing Costs and Benefits of Regulations

The AFR Education Fund wrote a letter to the FDIC regarding the analysis of costs and benefits, in which we urged the regulator not to impose a false and excessively narrow framework of “cost-benefit analysis” on their decisions. Download the letter here.

Letter to Regulators: AFR Ed Fund urges SEC to withdraw misguided proposed rules on proxy advisors and resubmission thresholds for shareholder proposals

Read or download the full PDF version of the letter. The AFR Education Fund sent a letter to the Securities and Exchange Commission opposing proposed changes to rules concerning proxy voting advisors and resubmission thresholds for shareholder proposals. Taken together, the changes will dramatically reduce the ability of shareholders to hold corporate CEOs accountable by