“This extensive concept release poses many questions concerning technical and detailed issues of disclosure. It is also part of a larger set of efforts relevant to financial disclosures, including the Disclosure Effectiveness Initiative, the Reg S-K study mandated by the JOBS Act, the recent proposed changes to materiality standards by the Financial Accounting Standards Board (FASB), and the lengthy and highly technical proposed rule on Disclosure Update and Simplification released on July 13th.”

“We appreciate the opportunity to comment on the proposed rule regarding incentive compensation in the financial industry. This proposal is a significant improvement over the 2011 version… However, we remain deeply concerned that loopholes in the regulation will allow a reckless Wall Street bonus culture to continue, putting taxpayers and the broader economy at risk.”

“Americans for Financial Reform (“AFR”) appreciates this opportunity to comment on the above referenced Supplemental Notice of Proposed Rulemaking (the “Proposal”) by the Commodity Futures Trading Commission (the “Commission”).

“Americans for Financial Reform (“AFR”) appreciates the opportunity to comment on the above mentioned Consultative Document. Among other issues, this Consultative Document proposes to change the measurement of derivatives risk exposures for leverage ratio purposes by replacing the Current Exposure Method (CEM) used today with the Standardized Approach to Counterparty Credit Risk (SA-CCR). The document implies that the SA-CCR has a more realistic approach to risk measurement, while the CEM is more conservative.”

“Americans for Financial Reform (“AFR”) and the Committee for Better Banks (“CBB”) appreciate the opportunity to comment on the Federal Financial Institutions Examination Council (“FFIEC”) notice of proposed revisions to the Uniform Interagency Consumer Compliance Rating System (“CC Rating System”).”