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.
In The News: Want To Make Payday Loans In States Where It’s Outlawed? Rent A Bank! (Talking Points Memo)
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.”
Letters to Regulators: Bank regulators should not weaken prudential rules for U.S. operations of foreign banks.
Regulatory agencies purport to “tailor” prudential rules, but they are severely undermining capital and liquidity requirements for foreign banks operating in the U.S.
Letters to Regulators: Joint Letter to the OCC Opposing Any Changes that Would Weaken the Community Reinvestment Act
On November 19, 2018, AFR and 35 organizations sent a joint letter to the OCC urging the agency not to weaken the Community Reinvestment Act.
The groups pressed the OCC that any changes to the CRA must strengthen — not weaken — banks’ obligation to meet the needs of low-income communities and communities of color and that changes must result in expanded access to credit in historically redlined areas.
The OCC proposal would dramatically limit the CRA’s effectiveness by distilling the complexity of the different credit needs of varied American communities to one numerical ratio and quantitative benchmarks, and would reduce public participation in the process that is fundamental to moving banks towards greater responsiveness to the needs of diverse customers and communities.
Joint Letter: 8 Organizations Warn Regulators Against Bank Payday Loans and Rent-a-Bank Arrangements
“Deposit advance” loans are payday loans, pure and simple, and data clearly show they create the same debt trap caused by non-bank payday loans. High-cost longer-term loans facilitated by banks and credit unions would also cause customers substantial harm. We also urge you to ensure that all financial institutions engaged in small dollar lending (1) limit interest rates to 36% or less, and (2) determine borrowers’ ability to repay their loans by assessing both income and expenses rather than engaging in collateral-based income-only underwriting.”
Letter to Congress: AFR Opposes A Dozen Deregulatory Bills in House Financial Services Committee Markup
AFR sent a letter opposing a dozen different deregulatory bills being marked up by the House Financial Services Committee. AFR Letter Re HFSC 11-14 Markup
AFR sent an opposition letter to HR 2148, which would have put loopholes in new rules designed to ensure that banks did not make excessively risky commercial real estate loans. HR 2148 Oppo letter
AFR sent the letter below to the House Financial Services Committee urging them to reject nineteen deregulatory bills. AFR Letter Re HFSC 10-11 Markup