Date: January 5, 2017

Issue: Capital Requirements / Commodities

To: Board of Governors of the Federal Reserve System

Filing Type: Comment Letter

Description: The letter expresses CCMC's significant disappointment with the Federal Reserve’s intention to impose new risk-based capital requirements on certain commodities activities of financial holding companies and their merchant banking investments.The proposal will have a deleterious effect upon growth and stability by creating barriers to traditional means of business financing and capital formation.

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