“The REINS Act is radical legislation that would upend decades of administrative law practices dating back to the New Deal era in the 1930s. The bill requires explicit approval of any ‘major regulation’ by both the House and Senate within 70 days in order for that rule to take effect. This requirement would create crippling barriers to administrative actions necessary to protect the public and implement the law.”
We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.
We are deeply concerned that the Investment Company Institute (ICI) Letter lays out a set of changes to the Proposed Rule which wold effectively negate the derivatives exposure limits in the rule and render them useless as a tool for controlling speculative leverage at registered funds, as is required by the 1940 Act. …This change would not simply modify the relative weighting of derivatives exposures, but would result in a massive increase in the absolute limit on derivatives risk exposure.
Americans for Financial Reform applauds the Department of Education’s final decision to de-recognize a major accreditor of for-profit colleges, the Accrediting Council for Independent Colleges and Schools (ACICS). The Department’s decision to no longer recognize ACICS is an important step toward ensuring that students and taxpayers do not bear the burden of illegal and fraudulent acts by for-profit colleges.
In the new political environment, it is likely that there will be a heavy emphasis on the capital formation mission of the SEC. The IAC should play a critical role in reminding the Commission that investor protection is crucial to stable and effective capital formation. …Improving financial entity disclosures is crucial if we are to improve market discipline for large financial entities and investor discipline for funds.
“Marcus Stanley of Americans for Financial Reform, a group that wants tougher regulation of Wall Street, said that the NEC and Treasury would provide the core economic policy advice to the new administration and would have a tremendous voice in future regulatory appointments. ‘Trump talked about the rigged system. [This] is a recipe for maintaining that rigged status quo,” he said.”
On behalf of Americans for Financial Reform (AFR), we are writing to oppose HR 5143, the “International Insurance Standards Act”. …Even without the amendment, HR 5143 places unreasonable and unworkable barriers on international negotiations important to the oversight of global insurance companies. We should not forget that an insurance company, AIG, was at the center of the 2008 financial crisis and received the largest taxpayer bailout in U.S. history. The $182 billion AIG bailout went to cover losses in investment banking type activities like the sale of credit default swaps and the securities lending business.
Americans for Financial Reform welcomes the news that the Department of Education has taken steps to protect both students and taxpayers by cutting off federal student loan money to Globe University and the Minnesota School of Business (MSB) — two for-profit institutions where the Department found
AFR joins 19 other organizations to express our opposition to H.R. 6392, the “Systemic Risk Designation Improvement Act of 2015.” This legislation increases the likelihood of big bank failures that could put at risk the economic security of millions of families.
“Far from improving systemic risk regulation, this legislation increases the likelihood of big bank failures that could put at risk the economic security of millions of families. It puts unprecedented new constraints on the ability of the Federal Reserve to provide basic oversight of large bank holding companies, including provisions that grant an unaccountable council of international regulators statutory powers over U.S. regulatory decisions. It would also politicize bank regulatory decisions, granting the Treasury Secretary of the incoming Administration new powers to pick and choose which big banks must follow basic safety rules.”