Americans for Financial Reform

Government Category: Comments & Letters to Regulators

Letter to the Regulators: Comment to Treasury FinCEN Supporting Greater Anti-Money Laundering Screening for Registered Investment Advisers, Exempt Reporting Advisers, and Family Offices

Americans for Financial Reform Education Fund wrote a comment supporting the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposals to require additional anti-money laundering and countering of financial terrorism (CFT) requirements for Registered Investment Advisers (RIA). We also encourage FinCEN to jointly propose rulemaking with the Securities and Exchange Commission (SEC) to require the collection of beneficial ownership as well as the creation of a Customer Identification Program (CIP). 

Letter to the Regulators: Letter to the SEC on Finalizing the ESG Funds Disclosures Rule to Protect Investors from Greenwashing and Other Misleading Claims

AFREF and 18 additional signatories wrote to the SEC in support of bringing much-needed disclosures to the vast market of ESG-designated products and services. The letter urges the SEC to finalize the rule titled “Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices” as soon as possible and recommends changes to the way the proposed rule addresses disclosure of metrics by ESG-Focused Funds. These changes would improve the rule by generating disclosures that better reflect ESG-Focused Funds’ varied strategies and priority metrics while alleviating concerns expressed by some commenters.

Letters to the Regulators: Letter in Support of The Financial Crimes Enforcement Network’s Rules Targeting Illicit Finance in U.S. Residential Real Estate Markets

View or download a PDF of the letter here. Americans for Financial Reform partnered with the FACT Coalition and 34 affordable and fair housing advocates to submit this letter in support of FinCEN’s strong draft rules targeting illicit finance in U.S. residential real estate markets, as well as the bureau’s recognition of the wide ranging

Letters to the Regulators: Letter Urging End to Overpayments to Insurance Companies and Financial Institutions

AFR joins a sign-on letter urging the Biden Administration to end billions of dollars in overpayments to insurance companies and financial institutions. These wasteful overpayments are causing significant challenges for Medicare’s financial sustainability. The fixes that CMS can and should undertake will help level the playing field between traditional Medicare and Medicare Advantage, promote health equity and bring down Part B premiums for everyone with Medicare.

Letters to Regulators: Letter to PCAOB in Support of Auditing Standards re: Company’s Noncompliance with Laws and Regulations

AFREF joined Public Citizen and other organizations in a letter to the Public Company Accounting Oversight Board (PCAOB) urging the board to strengthen and finalize its proposals to update AS 2405, A Company’s Noncompliance with Laws and Regulations, and AS 2110, Identifying and Assessing Risks of Material Misstatement. “The climate crisis and the economy-wide decarbonization

Letters and Statements: Letter to Basel Committee on Banking Supervision on Bank Climate Risk Disclosures

AFREF joined Public Citizen, The Sunrise Project and other partner organizations in a letter to the Basel Committee on Banking Supervision’s in response to its consultation paper Disclosure of climate-related financial risks. “Of particular importance is information related to financed emissions, transition plans, and forecasts. The proposal includes key measures to support disclosure of information