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
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.
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
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
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
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.
Letters to Regulators: AFR Ed Fund sent a letter opposing proposal to exempt foreign derivative clearing organizations from registration with the CFTC.
View or download a PDF version of the full letter.
On July 23, 2019, AFR Education Fund submitted a letter to the U.S. Securities and Exchange Commission (SEC) opposing a proposal that would create exemptions that would permit U.S. banks – and international banks active in the U.S. market – to do large-scale derivatives dealing in the U.S. without being designated as derivatives dealers under Dodd-Frank Act rules.
The requirement in the Dodd-Frank Act that major dealers in financial derivatives be regulated as such, and meet risk management and business conduct standards, is a direct response to derivatives market abuses that contributed to the 2008 financial crisis. The loophole created by today’s Final Rule could permit large-scale evasion of this requirement.