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Category: Letters to Regulators

AFR Letter on Leverage Rules for Swaps Dealers and Broker-Dealers
team-afrFebruary 22, 2013Letters to RegulatorsComments are off for this post

SEC faulted on proposed capital, margin, and segregation requirements for Security-Based Swap Dealers (“SBSDs”), and capital requirements for Broker Dealers.

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AFR Urges Increased Oversight of Money Market Mutual Funds
team-afrFebruary 15, 2013Letters to RegulatorsComments are off for this post

AFR submitted a comment letter to the Financial Stability Oversight Council urging an increase of oversight of money market mutual funds to address the systemic risk not fully addressed by current oversight rules.

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AFR Calls for Increased Consumer Protections in CFPB’s Trial Disclosures Proposal
team-afrFebruary 15, 2013Letters to RegulatorsComments are off for this post

AFR submitted a comment letter to the CFPB arguing for the need of rigorous consumer protections attached to any corporate field testing of new disclosure forms.

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AFR Letter: Resolution Plans Fall Far Short
team-afrJanuary 8, 2013Financial Reform News, Letters to RegulatorsComments are off for this post

More specificity and disclosure are needed in the big banks’ “living wills.”

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AFR Statement on SEC Approval of Copper ETFs
team-afrDecember 17, 2012Financial Reform News, Letters to RegulatorsComments are off for this post

As speculative interest increases, this vital industrial commodity will be withdrawn from the market, and prices for real-economy businesses and consumers will increase.

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Comments on Wells Fargo CRA Exam: Servicing and Mortgage Problems
team-afrDecember 7, 2012Financial Reform News, Letters to RegulatorsComments are off for this post

AFR joins 10 housing groups in asking OCC to downgrade Wells Fargo for its harmful mortgage and loan servicing practices.

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Comments on Wells Fargo CRA Exam: Payday Lending Problems
team-afrDecember 3, 2012Financial Reform News, Letters to RegulatorsComments are off for this post

OCC is asked to downgrade the bank over its Direct Deposit Advance loan product.

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Comment Letter on Margin Requirements for Uncleared Swaps
team-afrNovember 27, 2012Financial Reform News, Letters to RegulatorsComments are off for this post

AFR wrote to prudential regulators concerning margin requirements for uncleared swaps, calling for the strengths in the current proposal to be maintained and also for the proposal to be improved in a number of areas.

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Wide Range of Groups Oppose FHFA G-fee Proposal
team-afrNovember 27, 2012Financial Reform News, Letters to RegulatorsComments are off for this post

FHFA’s proposal to charge more in states with consumer protections has elicited letters of strong opposition from housing and consumer advocates, members of Congress, legal and policy experts, Attorneys General, state legislators, and others.

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AFR Letter on FHFA Guarantee Fees
team-afrNovember 27, 2012Financial Reform News, Letters to RegulatorsComments are off for this post

In a joint letter, AFR and allied organizations challenge FHFA plan to charge higher guarantee fees in states with strong consumer protection laws.

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