AFR Education Fund sent the letter below to the Securities and Exchange Commission opposing changes to rules governing how corporations can raise investment capital. These rules would make it easier for companies to raise capital without doing basic disclosures about their business or following other
The AFR Education Fund sent this letter to the Commodity Futures Trading Commission opposing new rules that would be ineffective in preventing speculation in energy and agricultural commodities. A pdf of the comment can be downloaded here: AFR Education Fund Comment on Position Limits Proposal
ACRE, AFSCME, the AFL-CIO, AFR Education Fund, the Consumer Federation of America, and Public Citizen sent a letter to the Municipal Securities Rulemaking Board concerning the need for broader public representation in governance of the Board and oversight of municipal lending markets. The letter is
Absent major changes, the Federal Reserve’s multi-trillion-dollar funding programs will reward corporate insiders and financial speculators, without guaranteeing desperately needed help for those hardest-hit by the coronavirus crisis. The Fed needs to set the right priorities for this credit and impose conditions that ensure the benefits of this extraordinary assistance go to those who need it most.
As organizations that represent the interests of American workers, small businesses, and consumers we applaud Representative Jayapal on a bill that finally puts American workers and small businesses ahead of corporations. This is exactly the type of program we need to keep people on payroll and connected to their important health benefits, address our ballooning unemployment, and lay the foundations for economic recovery.
Apart from the obvious fact that this is a public health crisis and should be treated as such, we should all be immensely skeptical of any suggestion from Wall Street that it needs a bailout or any kind of assistance. We need to help people, not profits.
In August regulators issued a rule that dramatically weakened the Volcker Rule limits on direct proprietary trading by banks. Today, they have proposed new changes that would greatly weaken restrictions on banks taking risks through ownership of external funds, including venture capital funds and securitization vehicles like collateralized debt obligations.
AFR Education Fund wrote a letter to banking regulators urging them to maintain risk controls for derivatives transactions at large banks Download the letter here. January 23, 2020 RE: Margin and Capital Requirements for Covered Swaps Entities (OCC Docket ID OCC–2019– 0023; Federal Reserve
We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.
AFR held a day-long convening of experts to discuss emerging issues in the SEC regulation of registered investment companies (mutual funds and Exchange Traded Funds that are registered under the 1940 Act).