Tag Archives: banking

Letters to Regulators: Letter to Treasury, OCC, FRB and FDIC on the Need to Fight Bank Consolidation

The President has made it clear: it’s time to fight consolidation, not facilitate it. In reviewing lessons learned from this most recent banking crisis to better prevent the next one, the regulators must be full-throated and clear in their affirmation that robust regulation and competition, not consolidation, will lead to a healthier, safer, and more vibrant financial system. Banks must exist to serve the needs of the American people, not the other way around – and it is regulators’ critical task to ensure so. 

Letters to Congress: Letter Opposing H.R. 3556 “Increasing Financial Regulatory Accountability and Transparency Act”

AFR sent a letter opposing H.R. 3556 “Increasing Financial Regulatory Accountability and Transparency Act,” a bill supposedly to make the Fed more transparent, which will instead hamstring the Financial Stability Oversight Council’s (“FSOC”) ability to effectively monitor risk in the financial system. This bill would subject the FSOC’s designation authority to Congressional review, which would allow any firm the FSOC designates as systemically important to lobby Congress to rescind the FSOC’s designation. This would render the FSOC designation authority under the Dodd-Frank Act futile and unnecessarily politicize the agency’s efforts to monitor companies that pose an outsized risk to our financial system. This bill comes at the heels of the FSOC’s announcement to reinvigorate its designation process, a welcome step in preventing the next financial crisis.

Letters to Regulators: Letter to FHFA on the Federal Home Loan Bank System

AFREF led 14 organizations in the housing, consumer protection, climate, civil rights, and community investment spaces, in a letter to the Federal Housing Finance Agency regarding the Federal Home Loan Bank system, arguing for expanded contributions to affordable housing to justify the public investment in the system, and for the system to undertake a number of initiatives to support members in reducing their climate risk and climate vulnerability.

Letter to Regulators: Silicon Valley Bank Failure Demonstrates the Need to Implement Key Executive Pay Rule, Dodd-Frank Section 956

AFREF, the Institute for Policy Studies, Global Economy Project, and Public Citizen led a letter with 22 additional signatories to the agencies tasked with implementing section 956 of Dodd-Frank. That section tasked six agencies with promulgating regulations to prevent incentive-based executive compensation that encourages “inappropriate risk” by May 2011.  Almost 12 years later, we don’t have a final rule. The letter was sent to regulators ahead of congressional hearings that will examine recent bank failures.

Factsheets: Climate Vulnerability and Banking

Climate change is a risk multiplier that exacerbates racial and economic inequality, and it is progressing at an alarming rate. Acute and increasingly frequent climate-related disasters, such as wildfires and hurricanes, as well as chronic issues such as heat stress, sea level rise, and drought,

Letters to Congress: Support for the Close the Shadow Banking Loophole Act 

AFR joined a joint coalition made up of consumer advocates and bank trade groups on this letter to Congress to express our support of the Close the Shadow Banking Loophole Act recently introduced by Senators Brown, Casey, and Van Hollen. This bill will close the Industrial Loan Company charter loophole that allows Big Tech and other large commercial firms from owning a bank without adequate oversight.