New: OSEC Produces House Rankings

Recent Actions

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 Systemtically 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 Systemtically 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 their 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.