Americans for Financial Reform

AFR Comment Letter to CFPB on High Cost Mortgage Loans

AFR submitted a comment letter to the CFPB on their proposed rules implementing Dodd-Frank changes regarding high cost mortgage loans. The letter argues against changing triggers for high cost loans for smaller loans which the statute allows but does not require, and argues that the proposal should be strengthened in various ways, including by making sure that borrowers in revolving lines of credit get the same protections as those in closed end mortgages.

More than 50 Organizations and Individuals Sign Letter of Opposition to S. 3468

AFR joined more than 50 organizations and individuals in signing onto a letter opposing S. 3468. The Independent Regulatory Analysis Act (S.3468) is a far-ranging proposal that would create major changes and lead to significant delays in the work of independent agencies. As all the major financial regulatory agencies are independent agencies this would have a profound effect on the progress of financial reform at agencies ranging from the Federal Reserve to the Securities and Exchange Commission.

AFR Comment Letter: Do Not Interfere With State and Local Use of Eminent Domain to Aid Homeowners

AFR wrote to the Federal Housing Finance Administration asking them not to interfere in state and local use of eminent domain to aid homeowners in restructuring underwater mortgages

AFR Letter: Oppose S. 3468 “The Independent Agency Regulatory Analysis Act”

AFR sent a letter of opposition to members of Congress regarding S. 3468, The Independent Agency Regulatory Analysis Act, which would give the Office of Information and Regulatory Affairs (OIRA) jurisdiction over all independent agencies in the federal government, including all of the financial regulatory agencies.

What’s Behind the American Banker’s new 501C4

AFR sent out this letter to our press list today. It concerns the American Bankers Association’s plans to establish a 501C4 focused on U.S. Senate races.

AFR Comment Letter: Designation of Swaps that Must be Cleared

AFR submitted a comment letter to the CFTC on the clearing mandate. This is the CFTC’s initial proposal for what derivatives will have to be cleared, and the CFTC has the ability to designate more swaps for clearing, which AFR recommends in the letter.

AFR Press Statement: SEC JOBS Act Proposal Fails to Address Investor Safety Concerns

Earlier today, the Securities and Exchange Commission (SEC) voted 4-1 to issue a proposed rule implementing the provision of the JOBS Act that allows the “general solicitation and advertising” (GS&A) of private stock offerings. Commissioner Luis Aguilar voted against releasing the proposal, pointing out that it did not include any of the enhanced protections suggested by commenters (such as CFA and AFR) to address the significantly increased investor vulnerability that will result from lifting the long-standing ban on these practices.

AFR Comment Letter: CFTC Derivatives Rules Must Apply to Foreign Affiliates

AFR submitted a comment letter to the CFTC regarding a rule that will determine whether the CFTC can regulate derivatives trading by foreign affiliates of US banks and corporations. Since derivatives trades move easily around the world and between affiliates and the parent company, it is important that US regulators be able to apply Dodd-Frank to such foreign trades. Our letter urged the CFTC not to let financial institutions escape derivatives rules by funneling transactions through their foreign affiliates.

Consumer Federation of America Press Statement In Response to SEC Announcement Regarding JOBS Act Rulemaking

In a major victory for investors, SEC Chairman confirmed earlier today that the Commission was changing course and would follow the traditional rulemaking procedures – proposing a rule and offering an opportunity for public comment – before lifting the solicitation ban.

Sign on Letter: JOBS Act Rulemaking Raises Complex Concerns

The JOBS Act rulemaking on the SEC’s schedule Aug. 22 raises a variety of complex issues that demand a full and transparent rulemaking process. The rushed approach to rulemaking reportedly contemplated by the agency would not allow for full consideration of these issues, and would therefore put investors at risk.