Category Archives: Letters to Regulators

Letter to Regulators: AFREF-EFF Letter to FTC on Private Equity takeover of .ORG

“PIR LLC will have to generate substantial additional revenue to service the debt which could force PIR LLC to take advantage of its monopoly position to raise prices to unsustainable levels, impose new service charges, reduce technical upkeep that could impair web connectivity or non-profit email traffic, or pursue other business strategies that could undermine the independence of non-profits including suspending or transferring domain names, in effect a censorship-for-profit strategy that has been used by other domain registries and internet companies.”

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Letter to Regulators: Assessing Costs and Benefits of Regulations

The AFR Education Fund wrote a letter to the FDIC regarding the analysis of costs and benefits, in which we urged the regulator not to impose a false and excessively narrow framework of “cost-benefit analysis” on their decisions. Download the letter here.

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Letter to Regulators: AFR Ed Fund Opposes Elimination of Derivatives Risk Controls

We strongly oppose the proposal to remove requirements to post initial margin when engaging in inter-affiliate derivatives transactions with covered swaps entities. The Agencies instituted this requirement just four years ago, concluding that these margin postings were necessary to “protect the safety and soundness of the covered swap entity in the event of an affiliated counterparty default”. Since this issue affects the key depository affiliates of the largest U.S. banks – entities at the heart of the taxpayer-supported safety net for systemically critical banks – the 2015 Final Rule also concluded that failing to require initial margin for inter-affiliate swaps would pose a threat to broader systemic stability.

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