Derivatives Archives - Americans for Financial Reform

News Release: CFTC Provides Carbon Market Guidance to Exchanges, But More Needs to Be Done

The Commodity Futures Trading Commission (CFTC) issued final guidance that outlines the terms and conditions that should be considered by designated contract markets (“DCMs”) when they list voluntary carbon credit (“VCC”) derivative contracts. The CFTC has rightly acknowledged the serious transparency and integrity challenges in the underlying, unregulated VCC market, but the guidance alone cannot prevent fraud and manipulation.

Letters to Regulators: CFTC Must Address Climate Risk, Carbon Offsets

Americans for Financial Reform Education Fund (AFREF) submitted two comments to the Commodity Futures Trading Commission (CFTC) in response to their request for information on climate-related financial risk as pertinent to the derivatives markets and underlying commodities markets. A coalition letter submitted jointly by AFREF, Amazon Watch,

Policy Recommendations: Recommendations for Systemic Reform to Create a Safe and Just Financial System

AFR released a recommended set of systemic reforms outlining steps to create a safe and just financial system. These include both reversing the deregulation of the Trump years and taking positive steps to create a far more secure and inclusive financial system. The full document

Letter to Regulators: New “Electronic Trading Risk Principles” Are Inadequate

The AFR Education Fund wrote a letter to the Commodity Futures Trading Commission regarding its proposed new “Electronic Trading Risk Principles”. The letter faulted the principles-based approach as basically allowing Wall Street to regulate itself in this important area. A copy of the letter can

Wall Street sign and a stoplight turned red - Photo by Roberto Júnior on Unsplash

News Release: CFTC Rule Dismantles Key Guardrail for Derivatives Market

Cross-border derivatives regulation is the latest area in which Trump appointees are systematically dismantling the post-2008 framework for regulation of Wall Street and the global “too big to fail” banks. Today, the Commodity Futures Trading Commission drastically weakened their rules governing the massive global markets for financial derivatives.

Letter to Regulators: AFR Education Fund Opposes Ineffective Rules to Control Commodity Speculation

The AFR Education Fund sent this letter to the Commodity Futures Trading Commission opposing new rules that would be ineffective in preventing speculation in energy and agricultural commodities. A pdf of the comment can be downloaded here: AFR Education Fund Comment on Position Limits Proposal

Letter to Regulators: AFR Education Fund letter to the CFTC regarding proposed rule on swaps registration thresholds and transaction requirements to cross- border transactions

The Americans for Financial Reform Education Fund wrote a letter to the Commodity Futures Trading Commission urging them to strengthen a proposed rule that would fatally weaken the implementation of Title VII of Dodd-Frank and its application to CFTC-regulated derivatives markets. In the letter, AFR Education

Letter to Regulators: AFR Supports Competitive Swaps Trading

The AFR Education Fund wrote a letter to the Commodity Futures Trading Commission supporting the agency’s proposal to require anonymous trading of cleared derivatives on Swaps Execution Facilities. Revealing the identity of trading partners can prevent new competitors from entering these markets and bidding down

Letter to Regulators: Don’t Weaken Derivatives Risk Controls

AFR Education Fund wrote a letter to banking regulators urging them to maintain risk controls for derivatives transactions at large banks Download the letter here. January 23, 2020 RE: Margin and Capital Requirements for Covered Swaps Entities (OCC Docket ID OCC–2019– 0023; Federal Reserve

Letter to Regulators: AFR Ed Fund Opposes Elimination of Derivatives Risk Controls

We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.