AFR submitted a comment to The Fed voicing concerns over the very weak proposal on emergency lending. In the letter we recommend that the Federal Reserve place specific advance limits on the length of time that an institution can rely on emergency lending, as well as better controls to limit lending to truly solvent institutions.
AFR submitted a comment letter to the CFTC, urging that they maintain oversight of derivatives transactions in the United States.
AFR submitted a letter to the SEC expressing deep concern that the rules proposed by the Commission regarding the JOBS Act fail to deliver important investor protections.
AFR submitted a comment letter to the financial stability board on plans for the aggregation of global derivatives data.
These comments responded to the request for comments on the proposed interagency policy statement that established joint standards for assessing the diversity policies and practices of entities regulated by the agencies. AFR found that while the creation of the OMWIs in the Dodd-Frank Act was incredibly important, the joint standards released by six of the federal agencies fell unfortunately short on specifics. In particular, the standards do not provide detail or uniformity, and are additionally lacking in accountability measures to ensure that the goals of increasing worker and supplier diversity are met.
AFR commented on the CFTC’s proposal to establish position limits to limit speculation that increases prices and volatility in markets for agricultural and energy commodities. AFR urged the CFTC to strengthen the rules to be more effective in preventing excessive speculation.
AFR submitted a comment letter to the banking regulators concerning their proposed rule requiring banks to hold liquidity reserves (extra funds to meet payment obligations in a stressed situation.)
“[W]e are troubled by the narrow scope of the Release and some of the assumptions underlying it. AFR believes that the Commission needs to consider the broader costs and benefits to the public of permitting ever-increasing speed and ubiquity of automated trading technologies. We believe that such an analysis would support stronger limitations on automated trading than appear to be contemplated…”
“[W]e thank you for your work in drafting an effective rule implementing section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Given that three years have passed since the enactment of the law , we urge you to move quickly to put the final rule in place.”
AFR joined the National Consumer Law Center, Consumer Federation of America, the Center for Responsible Lending, and 26 other consumer and civil rights groups call for stronger measures to stop banks and payment processors from helping internet and tribal payday lenders collect illegal payments from consumers’ bank accounts.