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AFR Market Risk Letter

This NPR implements provisions of the Basel III agreement relevant to the use of internal risk modeling to set risk-based capital levels for financial institutions. As a general matter, AFR is highly skeptical of the use of internal bank Value at Risk (VAR) models for setting capital requirements.

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AFR Statement on Passage of FY2011 Continuing Resolution

This continuing resolution does not give the Commodity Futures Trading Commission and the Securities and Exchange Commission all of the resources they need, but we are very pleased that the President and Congress fought to keep Wall Street reform on track and resisted efforts to starve them of the funds necessary to police the rules of the financial market.

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AFR SEC SEF Letter

A key objective of Title VII of the Dodd-Frank Act (DFA) is to create transparency in previously unregulated derivatives markets. Indeed, the transparency goal is apparent in the short title of the section – ―The Wall Street Transparency and Accountability Act‖. Transparency is a critical goal across the entire Dodd-Frank Act, and is mentioned in the overall purpose statement of the legislation.

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Servicing Consent Orders

The undersigned national labor, civil rights, consumer and community organizations call on you to withdraw the proposed consent orders issued to the nation’s mortgage servicers and to work with the state Attorneys General and United States Department of Justice to obtain a joint settlement that addresses illegal servicing practices in a meaningful manner.

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Adam Levitin CFPB Testimony

View the PDF Version Here Mr. Chairman Capito, Ranking Member Maloney, Members of the Subcommittee: My name is Adam Levitin, and I am an Associate Professor of Law at the Georgetown University Law Center in Washington, D.C., where I teach courses consumer finance, contracts, and

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Hilary Shelton CFPB testimony

Read the PDF Version Here “LEGISLATIVE PROPOSALS TO IMPROVE THE STRUCTURE OF THE CONSUMER FINANCIAL PROTECTION BUREAU” April 6, 2011 Good morning, Chairwoman Capito, Ranking Member Maloney, and so many of my good friends here on the Subcommittee. It is a pleasure and an honor

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CFPB Should Not Be Undermined

Republican lawmakers should stand down in their efforts to delay and obstruct the shaping of the Consumer Financial Protection Bureau, which if properly implemented will go down in history as the most significant and innovative change to come out of the Dodd-Frank financial reform law.