AFR Education Fund wrote a letter to banking regulators calling on them to withdraw a proposed rulemaking on the role of supervisory guidance. The letter criticized the new rule as unnecessary and potentially harmful, since it could limit the ability of bank supervisors to take
AFR released recommendations for “Day One” policy actions by the Biden Administration in the areas of banking regulation, securities and markets regulation, and addressing systemic risk. These are actions that could be taken without a lengthy rulemaking and would make immediate progress toward a fairer
The FDIC’s ILC rule threatens state-level consumer protections, further erodes the traditional separation between banking and commerce, and jeopardizes the safety and soundness of the financial system and the economy as a whole.
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
Every federal agency must dedicate all regulatory resources to addressing COVID-19 and the enforcement of rules meant to protect public health, consumers, investors and retirees, and the integrity and stability of the markets. The pursuit of any non-crisis-related rulemaking would be a misallocation of limited resources that distracts needed focus from U.S. public health and welfare, and financial stability.
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.
FDIC Chair Jelena McWilliams “is doing the bidding of loan sharks who have a decades-long history of trying to get around state consumer protection rules,” Americans for Financial Reform spokesperson Carter Dougherty observed. “And now a federal regulator is helping them do it.”