AFR, AFSCME, and the SEIU today sent the letter below to the Securities and Exchange Commission calling on the Commission to reproprose and strengthen its rules governing credit rating agencies. Conflicts of interest and deceptive practices at credit rating agencies were central to the 2008 financial crisis and continue to pose a threat to the economy today.
AFR and more than 100 consumer, civil rights, labor and community organizations submitted a letter to the CFPB urging the Bureau to issue a strong rule to address unfair, deceptive or abusive practices in the payday and small dollar loan market.
Americans for Financial Reform and the more than 100 undersigned consumer, civil rights, labor and community organizations write to urge the Consumer Financial Protection Bureau to issue a strong rule to address unfair, deceptive or abusive practices in the payday and small dollar loan market. In particular, it is essential that any rule encompass the longer-term, multi-payment products that are already evolving in an attempt to evade expected CFPB rules.
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.)