Date: July 20, 2016
Issue: Systemic Risk
To: The Honorable Janet Yellen, Chair, Board of Governors of the Federal Reserve
Filing Type: Regulatory
Description: We respectfully ask for a 45-day extension of the comment period for the advance notice of proposed rulemaking on capital requirements for supervised institutions significantly engaged in insurance activities (the “ANPR”). We strongly believe that an extension of the comment period is warranted in light of the novel and unique legal questions raised in the ANPR, many of which are being considered by stakeholders for the first time.