Date: March 21, 2016
Issue: Capital Requirements
To: Federal Reserve Board
Filing Type: Regulatory
Description: CCMC has commented extensively on capital, leverage, and liquidity rules issued by the Board of Governors of the Federal Reserve (the “Federal Reserve”) and other banking regulators in the past, with a particular focus on the impact of capital, liquidity and leverage standards upon the ability of non-financial businesses to raise the resources needed to grow and operate.
We support the intent of the countercyclical capital buffer (the “CCyB”)
proposal to increase the resilience of global systemically important banks. However,
we are concerned the CCyB proposal, as currently written, will unnecessarily harm
credit growth and far exceeds its intended purpose of acting as a supplemental
macroprudential tool to augment minimum capital requirements and other capital
buffers that are currently applicable to large, internationally active banking
organizations.