“As advocates for students, consumers, veterans, faculty and staff, civil rights and college access, we believe the systematic tracking and reporting of student and borrower complaints is essential to providing quality customer service, ensuring college and loan servicer and collector accountability, and preventing waste, fraud, and abuse of taxpayer dollars.”
“Americans for Financial Reform (“AFR”) appreciates this opportunity to comment Public Consultation on Non-Traditional Non-Insurance Activities and Products (the ‘Consultation’) by the International Association of Insurance Supervisors (the “IAIS”). We believe that improvements in insurance company regulation are necessary to address such systemic risks. “
“We commend the Commission and the Division of Swap Dealer and Intermediary Oversight staff for their work in compiling this Preliminary Report. We believe that the Commission should continue on the path laid out in the final rule and reduce the de minimis threshold to $3 billion after the $8 billion phase-in threshold terminates on December 31, 2017. We do not see sufficient evidence in the report to justify either maintaining the current level, or increasing it.”
We strongly support SEC action to improve oversight of potential liquidity issues in open-ended funds, and believe that the proposed rule should be adjusted in a number of ways to better achieve that end.
AFR is calling on financial regulators to provide the public with more transparency on the implementation of the Volcker Rule, the historic prohibition on bank proprietary trading incorporated into the Dodd-Frank Act.
“This week, the Commission faces key decisions in finalizing a crucial protection against derivatives risk, namely the rules governing mandatory provision of margin for derivatives transactions… In this letter, we wish to address one important area of these margin rules, namely requirements for inter-affiliate margin in transactions between swap dealers and affiliated entities. This issue has taken on increased prominence in recent months due to intense lobbying by major Wall Street banks to reduce or eliminate requirements for initial margin in inter-affiliate transactions. “