Federal Reserve – Americans for Financial Reform Education Fund

Letter to Regulators: The Fed must reject any effort by banks to increase involvement in oil and gas

afrc3adminApril 29, 2020Education Fund, Letters to RegulatorsComments are off for this post

Americans for Financial Reform Education Fund sent a letter to the Federal Reserve Board, urging them to avoid any actions which would permit the financial holding companies or any of their subsidiaries to directly or indirectly operate oil or gas companies. The letter highlights the manifold physical, economic, reputational and financial system risks of bank commodity holdings, risks have become even more severe with the recent dislocation in global energy markets. As these markets will be disrupted for an extended period, the letter asks the Board to firmly reject any effort by banks to use the situation with respect to defaulting loans in the energy industry to increase bank involvement in the oil and gas industry.

Letters to Regulators: AFR Ed Fund and Demand Progress Ed Fund Comments

afrc3adminNovember 8, 2019Education Fund, Letters to RegulatorsComments are off for this post

AFR Ed Fund and Demand Progress Ed Fund submitted comments to the Federal Reserve Board on faster payments.

Letter to Regulators: AFR Ed Fund and Demand Progress Ed Fund urge the Federal Reserve Board to enact strong consumer protections into their FedNow system

afrc3adminNovember 8, 2019Education Fund, Letters to RegulatorsComments are off for this post

The development of a real-time, ubiquitous payment system is an especially complex, expensive undertaking. Because of the scale of the endeavor, and its potential to impact the American public as a whole, we firmly believe the Board is the appropriate entity to establish a universal 21st century payments system.

Joint Letter: Letter to Federal Reserve Emphasizing Need for Strong Consumer Protections in Real Time Payment Systems

afrc3adminNovember 7, 2019Education Fund, Letters to RegulatorsComments are off for this post

Coalition letter urging the Federal Reserve to build in strong consumer protections into the design of its new real-time payment system

Letter to Regulators: AFR Opposes SoFi’s Deposit Insurance Application

team-afrJuly 19, 2017Letters to RegulatorsComments are off for this post

“…The essence of SoFi’s application is a request to seek the benefits of federal deposit insurance without subjecting SoFi itself or its private equity owners to the well-founded requirements for bank holding companies. The FDIC should not approve the application to facilitate this regulatory arbitrage. …If its application is granted, SoFi will be the first new ILC to secure deposit insurance in over a decade. That will send a clear signal to the marketplace that the FDIC intends once again to approve ILC deposit insurance applications. FDIC should not grant SoFi’s application and allow the ILC loophole to be revived.”

Letter to Regulators: AFR Urges Federal Reserve and FDIC to Take Opportunity to End Too Big to Fail

team-afrMarch 22, 2016Letters to Regulators, Statements and Press ReleasesComments are off for this post

“AFR sent a letter to banking regulators today concerning their review of bank resolution plans. The Dodd-Frank Act requires regulators to review these plans to ensure that major banks are no longer ‘too big to fail’ – that they can go through a conventional (Chapter 11) private bankruptcy in an orderly manner, without creating substantial economic disruption. “

Letter to Regulator: AFR Comments to Federal Reserve Urging More Capital for Large Banks

team-afrApril 3, 2015Letters to RegulatorsComments are off for this post

AFR provided comments to the Federal Reserve on a proposal to require more capital for the largest banks. While supporting the idea of additional capital for these banks, AFR’s comment criticized the level as too low.

AFR Letter: Mandatory Margin Requirements Needed for Uncleared Swaps

team-afrNovember 25, 2014Financial Reform News, Letters to RegulatorsComments are off for this post

“Mandatory margin requires participants in the swaps market to take full account of the risks of their derivatives transactions and provide some level of advance provisioning for such risks. The availability of properly segregated margin is clearly of enormous value in case of the default of a swaps counterparty.”

AFR Urges Federal Reserve to Act Against Bank Ownership of Commodities

team-afrApril 16, 2014Letters to RegulatorsComments are off for this post

“Americans for Financial Reform supports the separation of banking and commerce as a foundational principle, motivated both by considerations of preserving fairness in competition with non-bank firms who do not have access to the prudential safety net, and by considerations of financial safety and soundness.”

AFR Supports Enhanced Regulations for Foreign Banks

team-afrMay 1, 2013Letters to RegulatorsComments are off for this post

AFR submitted a comment letter supporting the proposed rules by the Board of Governors of the Federal Reserve System that set out enhanced prudential standards for foreign banking organizations and foreign non-bank financial companies.

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