View or download a PDF version of the letter. Consumer Federation of America AFL-CIO Better Markets Center for American Progress Americans for Financial Reform November 21, 2018 Dear Chairman Clayton: We are writing to express our grave concerns regarding PCAOB staff guidance on Rule 3526(b),
The AFR Education Fund wrote to the FDIC urging them to maintain comprehensive disclosure requirements for securitizations that are backed by depository banks. The agency is proposing to exempt private offerings from these requirements. Most of the toxic mortgage securitizations sold prior to the financial crisis were private offerings.
AFR AFL-CIO Comment on Securities Offering Concept Release S7-08-19 September 30, 2019 Vanessa Countryman, Secretary U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 RE: Concept Release on Harmonization of Securities Offering Exemptions, File No. S-07-08-19 To Whom It May Concern: The
This new paper does not contradict previous comprehensive studies finding that liquidity in the corporate bond market has been robust and has shown no signs of deterioration over the period in which the Volcker Rule was implemented. The OFR staff working paper does find evidence that banks affected by the Volcker Rule charge significantly lower markups for newly issued bonds they underwrite (that are exempt from most Volcker Rule restrictions on proprietary trading) than they do for other types of bond trades covered by the Volcker Rule.
“Private equity and hedge funds now wield enormous influence over the American economy, often with terrible consequences for workers and communities,” said Lisa Donner, executive director of Americans for Financial Reform. “We need effective rules of the road to stop predatory practices by these Wall Street giants.”
Americans for Financial Reform Education Fund raised concerns over weakening resolution planning requirements intended to prepare large bank holding companies for an orderly resolution in conventional bankruptcy without risk to financial stability and without any reliance on extraordinary public support of the failed bank or its counterparties.
Americans for Financial Reform Education Fund sent a letter to banking regulators opposing a proposal that would make the resolution planning process substantially less stringent than it currently is, and raising concerns over the safety and soundness of individual banks and the effect on U.S. financial stability.
Regulatory agencies purport to “tailor” prudential rules, but they are severely undermining capital and liquidity requirements for foreign banks operating in the U.S.
We commented to the banking regulators criticizing proposed rules on bank ownership of unsecured debt issued by systemically important (G-SIB) banks. This debt is intended to absorb losses in a potential future financial crisis, which may not be feasible if other banks are permitted to own significant amounts of it.
On Wednesday, Senator Sanders (I-VT) and Representative Lee (D-CA) introduced the Inclusive Prosperity Act, a bill that would impose a sales tax of 50 cents, 10 cents, and 1/2 a cent per $100 on each trade of stock, bonds and derivatives respectively.