Tag Archives: Systemic Risk

SEC Building

Letters to Regulators: Comment Letter in Response to the SEC’s Proposal on Swaps/Derivatives/13-F

AFREF sent a comment to the Securities and Exchange Commission calling for the agency to close long-running loopholes that have enabled certain hedge funds to use swaps and derivatives to avoid disclosing large positions which in turn can lead to coordinated attacks on companies and unnecessary volatility in the underlying prices of certain companies’ stocks. The implosion of family office Archegos Capital is emblematic of such a problem as its use of certain derivatives to build over an over 10% position of a company’s outstanding shares were never revealed until after it was forced to unwind and leading Globally Systemically Important Banks (G-SIBs) to take over $10 billion in losses as a result.

SEC Building

Letters to Regulators: Comment Letter Supporting the SEC’s Proposal to Expand Position Disclosure Requirements via Form PF

AFREF sent a comment to the Securities and Exchange Commission supporting the agency’s proposal to expand position disclosure requirements (via Form PF) for both hedge funds and private equity funds. Many of the disclosure exemptions were formed when both types of funds were fractions of the size they are today and would give the SEC and by extension, the Financial Stability Oversight Council (FSOC) critical information to prevent the uncertainty and threats to financial stability that we saw with Long Term Capital Management in 1999 as well as the financial crises of 2008 and March 2020.

the outside exterior of the U.S. Treasury Department building

Letters to Regulators: Letter to Secretary Yellen on Restoring FSOC’s Ability to Fully Execute its Authority Under Dodd Frank

AFREF and 30 allies sent a letter to Secretary of the Treasury Janet Yellen urging her to prioritize restoring FSOC’s ability to fully execute its authority under Dodd-Frank by repealing the SIFI 2019 guidance; developing a data strategy for OFR; and using the statutory authority given in Title I of Dodd-Frank to apply a racial equity lens when designating a non-bank financial company as a SIFI.