Americans for Financial Reform Education Fund, along with 25 undersigned organizations, is pleased to submit comments responding to the Joint Notice of Public Rulemaking (NPR) from the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively “the agencies”) regarding changes to the Community Reinvestment Act of 1977 (CRA).
“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”
“…We urged the Commission to be more aggressive in laying out structural reforms to the markets and more specific limits on dangerous automated trading practices. The current Supplemental NPRM does not change our basic assessment, as it maintains the basic framework of the 2015 NPRM, with no movement toward additional specificity in risk limits or risk control requirements or reduced discretion for market actors in designing and implementing risk controls…
We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.
AFR submitted a comment letter to the CFPB supporting their proposed guidance clarifying the relationship of their servicing rules to stronger state laws. The letter also makes suggestions for improvement.
AFR joined public interest groups in submitting a comment letter to the CFPB, arguing that additional information regarding private student loan servicing and collection is needed to design an effective loan modification program.
AFR submitted a comment letter to the Financial Stability Oversight Council urging an increase of oversight of money market mutual funds to address the systemic risk not fully addressed by current oversight rules.
February 22nd, 2011 Mr. David A. Stawick, Secretary Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington DC 20581 Ms. Elizabeth M. Murphy, Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-1090 Re: SEC File No. S7–39–10; Definition of
Read the PDF version here February 22nd, 2011 David A. Stawick, Secretary Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, NW Washington, DC 20581 Re: RIN 3038–AD10 – End-User Exception to Mandatory Clearing of Swaps Dear Mr. Stawick: On behalf of Americans for