Letter regarding the Center for Capital Markets Competitiveness’s Fix. Add. Replace. (FAR) Agenda

Sunday, April 7, 2013 - 8:00pm


The U.S. Chamber of Commerce, the world’s largest business federation representing the interests of more than 3 million businesses of all sizes, sectors, and regions, as well as state and local chambers and industry associations, and dedicated to promoting, protecting, and defending America’s free enterprise system, believes that effective regulation is needed to ensure the safety and soundness of the financial markets.

In 2007, the U.S. Chamber of Commerce established the Center for Capital Markets Competitiveness (CCMC) to advocate for the replacement of the existing early twentieth century era regulatory structure with one built to effectively regulate a globally competitive twenty-first century economy.

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) sought to address some of these challenges, but left in place the existing byzantine regulatory structure, even adding new layers and regulations. Almost three years later, Dodd-Frank is only one-third implemented, and the complexity and duplication is challenging to both regulators and the regulated.

Today, the CCMC released the Fix. Add. Replace. (FAR) Agenda to Fix the gaps and unintended consequences of Dodd-Frank, Add solutions for those issues that were ignored, and Replace flawed provisions of Dodd-Frank.

Some of the items in the FAR agenda include:


  • Establish checks and balances for the Consumer Financial Protection Bureau (CFPB)
  • Ensure that end-users of derivatives are able to manage financial risk
  • Make the Financial Stability Oversight Council more transparent, and better coordinate financial regulators
  • Strengthen money market funds to preserve essential cash management products
  • Preserve choice and affordability for retail investment and retirement savings
  • Ensure whistleblower rules do not undermine strong corporate compliance programs


  • Modernize the Securities and Exchange Commission
  • Streamline regulators through consolidation and process reforms
  • Require the CFPB to define the new abusive standard
  • Enhance global regulatory coordination
  • Ensure transparent, evidence-based corporate governance
  • Enfranchise retail shareholders
  • Improve financial reporting systems
  • The return of private sector housing financing


  • Repeal and replace the Volcker Rule
  • Ensure corporate governance compliance requirements are linked to long-term shareholder value
  • Ban mandatory audit firm rotation
  • Stop disincentives for investment and retirement savings, such as the Financial Transactions Tax

The Chamber looks forward to working with you to promote comprehensive financial regulatory reform.


R. Bruce Josten