“In numerous previous comments, AFR has raised serious concerns about the Commission rules and guidance that exempt foreign subsidiaries of U.S. banks, or U.S. subsidiaries of foreign entities that are highly active on Wall Street, from a wide range of Dodd-Frank derivatives rules. Given the global character of the derivatives market, we believe that such cross-border exemptions create the possibility for large-scale evasion of U.S. rules.”
“AFR supports this proposal to require the recovery of erroneously awarded executive compensation as a condition for exchange listing. Failures in corporate governance have been singled out by many observers, including the Financial Crisis Inquiry Commission, as a significant cause of the global financial crisis. “
“The undersigned consumer and civil rights organizations write to urge you to issue final prepaid card rules that prevent payday lenders and other predatory lenders from attaching dangerous credit features to the cards. We appreciate the strong elements of the proposed rules, which recognize that overdraft services are a form of credit and that credit accessed through cards must have the robust protections of the Credit CARD Act. While the proposed rules will stop some abuses, we are concerned that loopholes in the proposal can be exploited.”
“…responses to the RFI issued by the Department of the Treasury. The extraordinary diversity of on-line lending models and the rapid growth of the sector mean that continued monitoring will be necessary and the sector will likely fall into the purview of multiple regulators. We encourage the Treasury Department to remain active in determining the appropriate regulatory models, and we will further examine the responses to this RFI with interest to evaluate what types of regulation seem appropriate.”
“This is a huge problem – one that, over time, can easily add up to a difference of tens or even hundreds of thousands of dollars in retirement savings. Under the current rules, some of the financial professionals offering retirement investment advice are legally bound to look out for the best interests of their clients; but other professionals, while perceived as having such a duty and clearly benefiting from the perception, are free to put their own interests first, even if that means saddling their clients with needlessly high fees or inappropriate risks.”
“The undersigned consumer, student, education, and civil rights groups submit this comment in support of student loan servicing reform. Fair and accurate student loan servicing is crucial to protect student loan borrowers’ rights under the law and help them repay their loans successfully. “
“As discussed below, we do believe that this proposal outlines a significant rule change that could potentially reverse the statutory intention of the Dodd-Frank Act to provide a majority of independent members on the Board. We suggest that the Board extend the comment period to allow for more detailed examination of this proposal by members of the public interest community with an interest in municipal finance.”
“On behalf of Americans for Financial Reform, we are writing to urge you to reconsider and reverse the Treasury Department’s 2012 Determination that foreign exchange derivatives be excluded from Dodd-Frank regulations covering other forms of over-the-counter derivatives. “
“We, the undersigned national advocacy organizations representing consumers across America, very much appreciate the Chairman’s proposed Declaratory Ruling rejecting most of the requests by industry to undermine the essential protections of the Telephone Consumer Protection Act. “
“This letter seeks to engage the Department of Education on developing a proactive, risk-based, student-centered strategy for dealing with companies that the Department has reason to believe may be breaking the law and putting students and taxpayers in jeopardy.”