Letters to Regulators: AFR Education Fund letter to the CFTC regarding proposed rule on Swap Execution Facilities and Trade Execution Requirement

On March 15, 2019, Americans for Financial Reform Education Fund sent a letter to the Commodity Futures Trading Commission expressing several concerns regarding the agency’s “Swap Execution Facilities and Trade Execution Requirement” proposed rules. Read or download a PDF version of the letter.    

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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 […]

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Letter to Regulators: AFR Calls on CFTC to Forcefully Regulate High-speed Automated Trading

“…We urged the Commission to be more aggressive in laying out structural reforms to the markets and more specific limits on dangerous automated trading practices. The current Supplemental NPRM does not change our basic assessment, as it maintains the basic framework of the 2015 NPRM, with no movement toward additional specificity in risk limits or risk control requirements or reduced discretion for market actors in designing and implementing risk controls…

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AFR Letter: CFTC and SEC Must Act Against Derivatives “De-Guaranteeing” Ploy

“On behalf of Americans for Financial Reform (AFR), we write today to ask you to ensure appropriate regulatory oversight of derivatives transactions conducted through foreign subsidiaries of multinational Wall Street banks. In particular, we urge you to prevent the inappropriate classification of such derivatives as ‘non-guaranteed’ by the parent company, a classification which could exempt them from numerous critical derivatives regulations.”

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AFR Calls on Regulators to Ban Predatory High Frequency Trading

“[W]e are troubled by the narrow scope of the Release and some of the assumptions underlying it. AFR believes that the Commission needs to consider the broader costs and benefits to the public of permitting ever-increasing speed and ubiquity of automated trading technologies. We believe that such an analysis would support stronger limitations on automated trading than appear to be contemplated…”

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