Letters to Regulators: AFR sent a letter to the U.S. Commodity Futures Trading Commission criticizing a new de minimis threshold proposal

The de minimis exemption is a critical element of the swap dealer rule, as it determines which swap dealers will actually be designated as regulated swap dealers and subject to formal dealer oversight. This CFTC proposal addresses a wide range of issues surrounding this exemption. These range from the step-down from $8 billion to $3 […]

Read more
Letters to Regulators: AFR commented on Federal Reserve, OCC, FDIC proposed rule regarding the implementation of CECL accounting rules.

Americans for Financial Reform sent a letter to the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation commenting on a proposal to phase-in the regulatory capital effects of implementing the new Current Expected Credit Losses (CECL) accounting methodology. Click here to […]

Read more
Letters to Regulators: AFR commented on a proposal that would cut the minimum required leverage ratio at the largest U.S. banks.

Americans for Financial Reform sent a letter to the Federal Reserve Board of Governors and the Office of the Comptroller of the Currency to comment on a proposal that would reduce the minimum leverage ratio requirements for the largest U.S. banks. Click here to access a PDF version of the letter.  

Read more