Recent Actions
Comment Letter to OCC, FHFA, NCUA and FDIC Regarding Incentive-Based Compensation Proposal
November 20, 2024We submitted a letter to several financial regulators regarding their joint proposed regulations implementing Section 956 of the Dodd Frank Act. That statute prohibits certain incentive-based compensation arrangements among financial institutions. Section 956 is premised on a laudable and vital objective: holding financial institutions accountable for producing the crises of 2008 and March 2023 so that additional such crises may be averted. In its letter, OSEC advises that the regulators must implement a number of additional safeguards in the Proposed Rule. The letter can be found below:
Comment Letter to OCC and Federal Reserve Regarding Basel III "End-Game" Proposal
January 26, 2024We submitted a letter to the Office of the Comptroller of the Currency and the Federal Reserve Board regarding their joint proposal to implement the Basel III “end-game” regulatory capital rule. The U.S. is the only major banking power that has yet to implement “Basel III end-game” standards. In the letter, OSEC applauds the Agencies for finally implementing these global standards to improve the resilience of large banks as well as smaller banks with significant trading activities. The letter also commends the Agencies for proposing rules that would severely limits banks’ ability to rely on self-serving internal models for risk compliance purposes. Finally, OSEC reminds the Agencies that true safety and soundness will require the implementation of much higher capital requirements than those proffered by the Basel Committee. The letter can be found below:
Comment Letter to SEC Regarding Proposed Bitcoin ETFs
September 2, 2023We submitted a letter in response to the Securities and Exchange Commission’s (“SEC”) proposals to list and trade certain shares of bitcoin exchange-traded products (“ETFs”). In the letter, OSEC argues that the proposed ETFs primarily target retail investors, offering them access to bitcoin without the necessary safeguards. A significant portion of these retail investors may be lacking the technical expertise to engage with cryptocurrencies safely. OSEC commends the SEC for its cautious approach to cryptocurrency investments. The letter can be found below:
Comment Letter to FinCEN Regarding Rules for Disclosure of Non-Public Shareholder Information
February 13, 2023We submitted a letter in response to the Financial Crimes Enforcement Network’s (“FinCEN”) rule proposal regarding access to non-public shareholder information (“BOI”). In the letter, OSEC emphasizes that disclosure of shareholder information is necessary to prevent tax fraud and other illicit activity by wealthy bad actors. The letter can be found below:
Comment Letter to SEC Regarding Greenwashing by Funds and Advisers
August 17, 2022We submitted a letter to the Securities and Exchange Commission (“Agency”) for its proposed disclosure and reporting framework standards to combat greenwashing by investment companies and advisers. OSEC commends the Agency for its proposal and recommends that certain key provisions be strengthened. The letter can be found below:
Comment Letter to DOJ Regarding Bank Merger Review Process
February 8, 2022We submitted a letter to the DOJ urging it to drastically revamp the regulatory process for review of proposed bank mergers. Unfortunately, the banking agencies have become a rubber stamp for merger proposals. OSEC urges bank regulators to revise the merger review process to become less mechanical or metrics-driven, and to consider systemic risk metrics and community impact, as required under the relevant statutes. The letter can be found below:
Comment Letter to SEC Regarding Clawback of Executive Compensation
November 22, 2021We submitted a letter to the SEC’s re-proposed implementation of Section 954 of the Dodd-Frank Act, which requires the clawback of ill-gotten bonuses received by managers at public companies based on erroneous information. Section 954 is premised on laudable and vital objectives: reducing perverse incentives for risk-taking and enhancing public disclosure about compensation practices at public companies. OSEC commends the SEC for reopening the prior rule proposal, which contained numerous pro-industry interpretations. OSEC also recommends several important revisions to the rule proposal. The letter can be found below:
Comment Letter to CFPB Regarding Delay of Trump-Era Rules Implementing Fair Debt Collection Practices Act
April 20, 2021We submitted a letter to the CFPB commending that agency’s latest proposal to delay the effectiveness of Trump-era revisions to the agency’s Fair Debt Collection Practices Act rules. OSEC urges the CFPB to replace those rules with stronger consumer protections in light of the economic havoc caused by the COVID-19 pandemic. OSEC reminds the agency that the prior rules, though passed in late 2020 and approaching 1000 pages in length, contained only one passing reference to COVID-19, and entirely failed to consider the pandemic’s impact on consumers. Consumers subject to unfair debt collection practices have been in dire need of federal protection for years, and that need is even more pressing now. The letter can be found below:
Comment Letter to National Credit Union Administration Opposing Derivatives Regulation
December 28, 2020We submitted a comment letter to the National Credit Union Administration (NCUA) criticizing that agency’s proposed derivatives regulation, which would invite federal credit union (FCU) managers to significantly increase their investments in risky derivatives. OSEC reminds the NCUA that the non-profit nature of credit unions is no guarantee that these institutions are free from incentives to take on excessive risk. While incentive-based bonuses are more common at banks, they are not unusual in credit unions. Thus, many credit union managers have incentives to engage in the same kind of speculative behavior that caused the Great Recession of 2008. Depositors join credit unions instead of banks largely because the former are known for their fiscal austerity. Indeed, it would come to the surprise of many FCU members that the NCUA permits credit unions to invest in derivatives at all. The letter can be found below:
Comment Letter to Employee Benefits Security Administration Opposing Dilution of Shareholder Rights
September 16, 2020We submitted a comment letter to the Employee Benefits Security Administration (“EBSA”) criticizing that agency’s proposal entitled “Fiduciary Duties Regarding Proxy Voting and Shareholder Rights.” The proposed rule requires that plan fiduciaries act “solely in accordance with the economic interest of the plan.” OSEC argues that the EBSA must clarify that the appropriate investment horizon will be very long-term in many cases, especially given the fact that retirement plans are typically held for years or decades prior to termination. We also urge the EBSA to advise fiduciaries that the “economic impact” standard established in its proposal likely includes climate change related impacts. The letter can be found below:
Comment Letter to Financial Regulators Opposing Expansion of Hedge Fund Exemptions in Volcker Rule
April 29, 2020We submitted a comment letter to the Federal Reserve, the SEC, the FDIC, the CFTC and the OCC in response to a notice seeking public comment on proposed regulations that would greatly expand existing exemptions in the Volcker Rule for hedge funds, venture capital funds, and loan securitizations. As the nation heads into another recession, caused by the COVID-19 pandemic, structural reforms like the Volcker Rule are going to prove more important than ever to safeguard the economy. The letter can be found below:
Amicus Brief to U.S. Supreme Court in Retirement Plans Committee of IBM v. Jander
October 1, 2019We submitted an amicus brief in
Retirement Plans Committee of IBM v. Jander, a case presently pending before the U.S. Supreme Court. The brief argues that the duty of disclosure under ERISA should not be constrained by securities disclosure laws or the mere fact that ESOP fiduciaries may be acting in a corporate capacity. The fiduciary duties established under ERISA are an important bulwark against imprudent decisions made within the rarefied confines of corporate suites. This case involves an important legal standard that, if interpreted wrongly, could handcuff the ability of aggrieved investors in ESOPs to find justice through the courts for malfeasance committed by individuals entrusted with the care of plan assets. The brief and the accompanying press release can be found below:
Comment Letter to CFPB Regarding Debt Collection Regulations
August 30, 2019We submitted a letter to the CFPB criticizing that agency’s proposal to establish weak
regulations implementing the Fair Debt Collection Practices Act (FDCPA). OSEC argues while the proposal contains some beneficial provisions – such as restrictions on debt collection
through social media and a once-per-week limitation on conversations with debt collectors – it nevertheless contains
a number of troubling features that should be reconsidered or revised. The letter can be found below:
Comment Letter to CFPB Regarding Payday Lending Rule
April 16, 2019We submitted a letter to the CFPB criticizing that agency’s latest proposal to repeal the mandatory underwriting provisions contained in its November 2017 Payday Lending Rule, which established consumer protections for payday loans. OSEC argues that the latest proposal’s is fatally flawed under prevailing principles of administrative law. The letter can be found below:
Comment Letter to Financial Regulators Regarding Proposed Weakening of the Volcker Rule
October 17, 2018We submitted a comment letter to the Federal Reserve, the SEC, the FDIC, the CFTC and the OCC in response to a notice seeking public comment on proposed regulations that would weaken the Volcker Rule. Millions of lobbying dollars have been spent by industry participants to cajole these agencies into diluting the Volcker regulations. These efforts have culminated in the latest proposed regulations, which would significantly stymie the Volcker Rule’s effectiveness. In its letter, OSEC vociferously objects to this naked attempt at deregulation. The letter can be found below:
Comment Letter to SEC Regarding the Standard of Conduct for Broker Dealers
August 9, 2018We submitted a letter to the SEC criticizing that agency’s Regulation Best Interest (“Reg BI”) – a deeply flawed proposal that defines the standard of conduct that would apply to broker-dealers when making recommendations about securities to retail customers. OSEC argues that, by failing to adopt the fiduciary standard for broker dealers, the SEC has failed to meet its stated goal of protecting retail customers. The letter can be found below:
Comment Letter to Federal Reserve Regarding Supervisory Guidelines for Bank Risk Managers
March 15, 2018We submitted a comment letter to the Federal Reserve Board regarding the agency's proposed supervisory guidance for senior management at large financial institutions (“LFIs”). The Fed's supervisory guidance is an important part of the agency's attempts to manage market risk. While the proposed guidance covers many areas, it falls short on a number of key points that are highlighted in OSEC's letter. For instance, OSEC has recommended that the Fed's guidance require external audits and expanded executive compensation restrictions to help avoid the kind of conditions that caused the last financial crisis. The letter can be found below:
Comment Letter to OCC Regarding Volcker Rule
September 22, 2017We submitted a comment letter to the Office of the Comptroller of the Currency (“OCC”) in response to that agency’s notice seeking public input on the Volcker Rule. The Volcker Rule was passed as part of the Dodd Frank Act of 2010 in order to help avert another financial crisis similar to the Great Recession of 2008. Of the five federal agencies charged with implementing the Volcker Rule, the OCC has demonstrated itself to be the most bank-friendly. In its comment letter, OSEC has forcefully reminded the OCC that the Volcker Rule has statutory backing, and as such is immune from many of the deregulatory moves proposed by the OCC in its Notice. The letter can be found below:
Comment Letter to CFPB Regarding Credit Card Reforms
June 8, 2017We submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) regarding that agency’s request for comment on credit card industry regulations. While the CARD Act of 2009 has curtailed certain abusive practices, problems persist. In this letter we highlight a few areas that merit increased scrutiny from the CFPB. The letter can be found below:
Petition to Congress and the President Demanding the Safeguarding of the Dodd-Frank Act
March 18, 2017We organized a petition asking the President and Congress to oppose Rep. Jeb Hensarling's Choice Act 2.0. That bill (like its earlier iteration from last year) would effectively repeal the Dodd-Frank Act, which currently contains many protections for ordinary investors, consumers and debtors. If passed, the Choice Act would serve as little more than an outright gift from Congress to Wall Street bigwigs. Among other dangerous provisions, the Financial Choice Act would repeal the Volcker Rule, thereby allowing banks to resume speculative trading using taxpayer-insured deposits and free money from the Federal Reserve. A link to the petition can be found below:
Occupy the SEC's Response to the Current Financial/Political Climate
January 7, 20172016 came to a close with an unexpected and disorienting political transition. The results of the 2016 U.S. Presidential Election challenge notions of democratic governance and threaten to upend much-needed financial regulation. We are issuing a call to action to members to help us promote a fair financial system, confront the false promises of President-elect Trump on infrastructure and the economy, and build a movement for a better financial system and economy.
FOIA Request to SEC Requesting Lobbying Documents
December 16, 2016Section 621 of Dodd Frank Act required the SEC to implement a rule prohibiting conflicts of interests in certain securitization transactions. Congress gave the SEC until early 2011 to finalize the regulation. On September 19, 2011, the Commission published Proposed Rule 127B to implement Section 621. But over five years have passed and the SEC has still not finalized the rule. OSEC has reason to believe that members of the securities industry have succeeded in lobbying the Commission to delay the finalization of this politically unpopular (but vital) regulation. OSEC has issued a request to the SEC under the Freedom of Information Act (FOIA) to bring those lobbying efforts to light.
OSEC RepRank - Scoring for Every Member of the U.S. House of Representatives on Financial Reform
November 1, 2016Two years ago, Occupy the SEC (“OSEC”) unveiled "RepRank," a scoring system that assigned a score of 0-100 to all members of the House of Representatives in the then-current 113th Congress of the United States.
With nationwide elections one week away,
OSEC has updated RepRank to include scores for all members of the current House of Representatives (114th Congress), which includes numerous incumbents seeking re-election on November 8. RepRank also identifies what percentage of each House member's donations derive from financial industry sources.
Amicus Brief to U.S. Supreme Court in Salman v. United States
August 28, 2016We submitted an amicus brief in
Salman v. United States, a case presently pending before the U.S. Supreme Court. The brief argues that gratuitous tips of inside information should serve as the basis for insider trading convictions. Otherwise, the friends and families of company insiders will be free to profit from secret company information, without liability. Retail investors, pensioners and other non-insiders cannot fairly compete in the securities markets under such conditions. The brief and the accompanying blog post can be found below:
Comment Letter to Federal Regulators Regarding Excessive Bonuses
July 25, 2016We submitted a comment letter to six federal agencies, including the Federal Reserve and the Securities and Exchange Commission, regarding those agencies' implementation of Section 956 of the Dodd-Frank Act. Section 956 prohibits financial institutions from paying their employees "excessive compensation" that could put the company at risk. This statute was passed by Congress as a reflection of the public’s anger over the profiteering culture on Wall Street. In our comment letter, we urge financial regulators to pass a tough rule that vindicates the American public’s interest in fair markets and equitable compensation for financial professionals. The letter can be found below:
Petition to Congress in Opposition to the Repeal of the Dodd-Frank Act
June 8, 2016We organized a petition asking Congress to oppose the Financial Choice Act, which was recently proposed by Rep. Jeb Hensarling. That bill would effectively repeal the Dodd-Frank Act, which currently contains many protections for ordinary investors, consumers and debtors. If passed, the Financial Choice Act would serve as little more than an outright gift from Congress to Wall Street bigwigs. Among other dangerous provisions, the Financial Choice Act would repeal the Volcker Rule, thereby allowing banks to resume speculative trading using taxpayer-insured deposits and free money from the Federal Reserve. A link to the petition can be found below:
Comment Letter to SEC and FDIC Regarding Orderly Resolution of Broker Dealers Under Dodd-Frank Title II
May 2, 2016We submitted comment letters to the Federal Deposit Insurance Corporation (“FDIC”) and the Securities and Exchange Commission (“SEC”) regarding those agencies’ proposed regulations implementing Section 205 of the Dodd-Frank Act (“DFA”). Section 205 of the DFA contains vital provisions that, if properly implemented, would help address the troublesome risks presented by “Too Big to Fail” (“TBTF”) broker-dealers. The letter and the accompanying press release can be found below:
Comment Letter to US Trade Representative on the Employment Impact of the Trans Pacific Partnership (TPP)
January 13, 2016We submitted a comment letter to the US Trade Representative regarding the impact that the Trans Pacific Partnership Agreement (TPP) will have on US employment. Specifically, OSEC argues that the TPP will exacerbate income inequality and undermine the wages of low-skilled workers in the United States. Further, we argue that the TPP permits financial institutions to undermine prudential regulation, which could lead to the next financial crisis. The letter can be found below:
Petition to Congress in Opposition to Deregulatory Riders to the Omnibus Government Spending Bill
December 14, 2015We organized a petition asking Congress to oppose various deregulatory riders to the omnibus government spending bill. These riders would, among other things, weaken the regulatory authority of the CFPB, DOL, FSOC and Federal Reserve. A link to the petition can be found below:
Petition to Congress in Opposition to H.R. 4002 ("Criminal Code Improvement Act of 2015")
November 18, 2015We organized a petition asking Congress to oppose H.R. 4002 ("Criminal Code Improvement Act of 2015"), a bill that would serve as a "Get Out of Jail Free" card for white collar criminals. If the bill is enacted, white collar criminals would be able to evade punishment for a host of crimes, EVEN IF they acted with negligence, gross negligence, or recklessness. A link to the petition can be found below:
Comment Letter to CFTC Regarding Aggregation of Position Limits
November 13, 2015We submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) regarding that agency’s notice of re-proposed rulemaking regarding aggregation of position limits on certain commodities contracts and derivatives. The proposed position limits regime is already rife with numerous exemptions, such as broadly permissive provisions for hedging. The CFTC has now proposed an aggregation scheme that would make it even easier for large commodities players to utilize subsidiaries and shell companies to monopolize commodity markets, while evading detection from the agency. Our letter urges the CFTC to utilize a reliable ownership-based test to establish sensible aggregation guidelines. The letter can be found below:
Comment Letter to SEC on Exchange Traded Products
August 28, 2015We submitted a letter to the Securities and Exchange Commission in response to that agency's request for comment on Exchange Traded Products. We argue that the ETP market, which currently constitutes over a quarter of U.S. equity trading by dollar value, is in dire need of enhanced regulation. It is paramount that the SEC espouse policies that permit everyday, retail investors to compete on an equal footing with sophisticated ETP
underwriters and other parties enjoying information advantages. The letter can be found below:
Comment Letter to Department of Labor Regarding its Proposed Implementation of Fiduciary Rule
July 22, 2015We submitted a letter to the Department of Labor regarding that agency’s proposed fiduciary rule, which would significantly change the standard of conduct that applies to investment advisers dealing with certain retirement accounts. We urge the agency to avoid adopting a contrasting approach that pays lip-service to the heighted fiduciary standard while simultaneously shackling that standard with sweeping exemptions that resurrect the old suitability standard. The letter can be found below:
Petition to Senate and the President Requesting the Appointment of a Progressive as SEC Commissioner
July 10, 2015We organized a petition asking the Senate and the President to ensure that the upcoming vacancy for the post of SEC Commissioner is filled with a regulator who has demonstrated commitment to financial reform. Our country needs an SEC Commissioner who possesses a strong record of advocating for the protection of consumers and investors. A link to the petition can be found below:
Comment Letter to FSB/IOSCO on Systemic Risks in Asset Management
June 15, 2015We submitted a letter to the Financial Stability Board (“FSB”) and the International Organization of Securities Commissions (“IOSCO”) recommending that these international regulators address the systemic risks posed by global asset managers. In its letter, OSEC points to weaknesses in the measures that these regulators have proposed to designate asset managers or funds as Globally Systemically Important Financial Institutions (G-SIFIs). OSEC also urges the FSB/IOSCO to pursue industry-wide regulatory measures to address systemic risks that asset managers pose.
Comment Letter to FSOC on Systemic Risks in Asset Management
April 28, 2015We submitted a comment letter to the Financial Stability Oversight Council (FSOC) in response to that agency’s request for comment on the systemic risks posed by the asset management industry. Asset managers have created, propagated and amplified systemic risk during past crises. While some past weaknesses have been addressed by the Dodd-Frank Act, many such weaknesses have not, and the markets have recently seen many developments that could create new risks.
Amicus Brief to U.S. Supreme Court in <i>Bank of America v. Caulkett</I>
March 23, 2015We submitted an amicus brief in
Bank of America N.A. v. Caulkett, and
Bank of America N.A. v. Toledo-Cardona, two consolidated cases presently pending before the U.S. Supreme Court. These cases focus on Sections 506(a) and 506(d) of the Bankruptcy Code, which, if read together, provide that a completely underwater lien must be voided under a Chapter 7 process. An unfavorable decision in the case would hurt 2.1 million underwater borrowers who are at risk of impending default and possible foreclosure on their homes. The brief and the accompanying blog post can be found below:
Petition to Congress Against H.R. 37
January 14, 2015We organized a petition asking Congress to oppose H.R. 37, a smorgasbord of amendments that would gut key portions of the Dodd-Frank Act. While proponents of H.R. 37 argue that it is merely a collection of technical amendments to Dodd-Frank, the fact is that many of these changes would embolden regulated financial companies to continue undertaking the kind of risky financial activities that led to the Great Recession of 2008. The bill embodies the first salvo in the Republican-dominated 114th Congress bid to bring about the death of Dodd-Frank through a thousand cuts.
A link to the petition can be found below:
Petition to Congress Regarding Dodd-Frank Deregulation
December 10, 2014We have organized a petition asking Congress to oppose current attempts to roll-back crucial parts of the Dodd-Frank Act. Specifically, the petition opposes Section 630 of the Senate Amendment to H.R. 83 (Omnibus Bill) and Title III of the Houses current version of the Terrorism Risk Insurance Act of 2014 (TRIA). Section 630 would gut Dodd-Franks swaps pushout rule, and Title III would free so-called end-users from margin requirements in derivatives trading. If passed, Section 630 would increase the chances that risky derivatives trading would once again require government bailouts. Similarly, Title III would proliferate credit risk from discrete end-users to the broader global economy. These provisions are nothing more than an attempt by Wall Street lobbyists and their friends in Congress to eviscerate important derivatives reforms implemented by the Dodd-Frank Act.
Links to the petition and the accompanying letter can be found below:
Letter to Congress Regarding Private Bonuses for Public Employment
December 8, 2014We submitted a letter to members of Congress, asking them to help close the spinning revolving door that exists between the private sector and government agencies. Specifically, the letter seeks to raise attention to morally bankrupt deferred compensation schemes through which private sector companies are able to indirectly influence executive branch employees. In its letter to Congress, OSEC advocates that language be added to Section 209 of Title 18 that specifically prohibits an executive branch employee from receiving any private sector bonus that rewards the acceptance of a government position, regardless of whether the bonus is paid before or during government employment.
The letter and the accompanying press release can be found below:
Comment Letter to Securities and Exchange Commission Regarding Liquid Alternative Mutual Funds
November 25, 2014We submitted a letter to the Securities and Exchange Commission (“SEC”), recommending that the agency promulgate tough new regulations covering so-called “liquid alternative” mutual funds. In our letter, we warn the SEC about the outsized risks that these alternative funds present to investors and the economy. “Liquid alts” are a variety of mutual funds that promise high yields to investors, based on the utilization of risky investment strategies typically favored by the likes of hedge funds. These alternative funds have grown in popularity and growth estimates anticipate assets in liquid alternatives to amount to $2 trillion by 2020.
The letter and the accompanying press release can be found below:
Amicus Brief to U.S. Supreme Court in Omnicare v. Laborers
September 5, 2014We submitted an amicus brief in
Omnicare, Inc. v. Laborers District Council Construction Industry Pension Fund, a case that is currently pending before the U.S. Supreme Court. The case centers on a key provision of the Securities Act of 1933 , Section 11, which creates an express right of action against issuers and their agents for material misrepresentations contained in the offering materials of registered securities. Section 11 is an important tool that aggrieved investors can use to seek remedy for misleading statements made by issuers and their agents. For example, Section 11 has been extensively used to combat the sort of shoddy-mortgage backed securities that led to the last recession. The brief and the accompanying press release can be found below:
Comment Letter to Commodity Futures Trading Commission Regarding Position Limit Regulations
August 7, 2014We submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) regarding that agency’s notice of re-proposed rulemaking regarding position limits on certain commodities contracts and derivatives. Unfortunately, the proposed position limits regime is rife with numerous exemptions, such as broadly permissive provisions for hedging. The CFTC’s proposed rules also fail to adequately regulate commodities speculation in non-spot months. In its comment letter, OSEC has recommended that the Commission promulgate simple and effective per se regulations that are both transparent and useful in regulating market conduct.
The letter and the accompanying press release can be found below:
Comment Letter to Securities and Exchange Commission Regarding Clearing Agency Regulations
June 10, 2014We submitted a comment letter to the SEC regarding its request for comments on the its proposed clearing agency rules. As numerous commentators have asserted, swaps and other exotic OTC derivatives contributed to the recent financial crisis. The Dodd Frank Act has sought to shed light on these opaque markets, by requiring derivatives to be cleared through registered agencies. In some ways the risk associated with derivatives has not gone away - it has simply shifted to clearing agencies. Thus, it is vital that the Commission not only promulgate strong regulations covering such agencies, but also enforce such regulations in a vigorous manner.
The letter and the accompanying press release can be found below:
Comment Letter to Federal Reserve Regarding Commodities Regulations for Banks
March 29, 2014We submitted a comment letter to the Federal Reserve regarding its request for comments on the current state of commodities regulation vis-a-vis banks and Systemically Important Financial Institutions ("SIFIs"). As noted in our letter, banks must divest from commodities activities because the current status quo features a plethora of risks including:
- system-wide proliferation of discrete environmental risks
- market domination and antitrust risks
- systemic magnification of commercial tail risks
The letter and the accompanying press release can be found below:
Comment Letter to FDIC Regarding the Resolutions of Too Big to Fail Institutions Under Title II of Dodd Frank
March 18, 2014We submitted a comment letter to the FDIC regarding its proposed rule implementing Title II of the Dodd Frank Act, which covers the orderly resolution of Systemically Important Financial Institutions ("SIFIs") without putting any burden on taxpayers. OSEC has recommended that the FDIC impose stringent conditions on troubled SIFIs under resolution.
Comment Letter to Financial Regulators Regarding the Treatment of TruPS CDOs in the Volcker Rule
February 12, 2014We submitted a comment letter to the financial regulators regarding the recent concessions made to the industry on how to treat TruPS CDOs in the Final Volcker Rule.
Letters to Congress Regarding the "Fairness for Community Job Creators Act"
January 21, 2014We submitted letters to both the House and Senate regarding companion bills that would carve out an exemption in the Volcker Rule for TruPS CDOs.