“AFR strongly supports measures to both limit and control risks of physical commodity involvement at financial holding companies. …Specifically, we support the new consolidated limits on the total size of commodity holdings, the capital increase to 300 percent risk weights applied to commodities held under 4(k), and more…”
We strongly support using Consolidated Foreign Subsidiary (FCS) status as the basis for cross border enforcement rather than the more amorphous and subjective “guaranteed subsidiary” status. …We strongly disagree with the Commission’s proposal to exclude a wide range of transactions involving foreign branches and affiliates of U.S. swap dealers from external business conduct requirements.
In an Oct. 23 letter, AFR urged the Securities and Exchange Commission not to to approve the organization and marketing of a commodity Exchange Traded Fund based on the storage of physical copper. Allowing speculators to hoard this vital industrial metal would damage the economy and set a dangerous precedent, the letter warned.