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.
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.
We strongly disapprove of the new proposal to change rules for derivatives trading announced in today’s meeting of the Commodity Futures Trading Commission (CFTC). The requirement that complex derivatives be traded whenever possible in open, competitive markets was a crucial element of Dodd-Frank derivatives market reforms.
A look back at the financial lobby’s robotic opposition to one proposed reform after another, and how Wall Street’s claims have squared with real-world events. This new AFR report homes in on three pre-financial-crisis case studies, involving credit cards, mortgages, and derivatives.