Comment Letters
CCMC regularly engages regulators through their comment and notice periods. Below are the recent comment letter submitted on behalf of the business community. Click here to see all the comment letters.
Letters are organized by topic/issue
| Accounting and Auditing | Derivatives |
| Corporate Governance | Systemic Risk |
| Executive Compensation | Regulatory Reform |
| Money Market Mutual Funds | Volcker Rule |
| CFPA/CFPB | Misc |
| Capital Formation | |
- Joint Comment Letter to IASB and FASB Regarding Proposed Accounting Standards Update on Leases. (PDF) April 25, 2012
- Joint Comment Letter on Mandatory Audit Firm Rotation.. (PDF) April 19, 2012
- Comment Letter to PCAOB Regarding Proposed Auditing Standard Related to Communications with Audit Committees. (PDF) February 29, 2012
- FIRCA Letter to the PCAOB Audit Firm Rotation. (PDF) February 23, 2012
- FIRCA Letter to SEC Regarding Audit Firm Rotation. (PDF) February 23, 2012
- Coalition Letter Regarding Lease Accounting to the Senate Committee on Banking, Housing and Urban Affairs and the House Committee on Financial Services. (PDF) February 17, 2012
- Comment Letter to FASB on Proposed Accounting Standards Update on Financial Services Investment Companies and Proposed Accounting Standards Update on Real Estate Property Entities (PDF) February 8, 2012
- Coalition Letter in Opposition to the Premium Capture Cash Reserve Account in the Risk Retention Proposed Rule. (PDF) January 20, 2012
- Letter to the PCAOB on Improving the Transparency of Audits. (PDF) Janurary 9, 2012
- Letter to FASB Extension Request for Proposed Accounting Standards Updates. (PDF) December 2, 2011
- Letter to Chairman Bachus and Ranking Member Frank on H.R. 3213, the "Small Company Job Growth and Regulatory Relief Act of 2011"
- Comment Letter to FINRA on Proposed Amendment to NASD Rule 2340 to Address Values of Unlisted Direct Participation Programs and Real Estate Investment Trusts in Customer Account Statements. (PDF) November 11,2011
- Comment Letter to the PCAOB Regarding Concept Release on Auditor Independence and Audit Firm Rotation and Notice of Roundtable. (PDF) October 20, 2011
- Comment letter to the PCAOB Regarding Concept Release on Possible Revisions to PCAOB Standards Related to Reports on Audited Financial Statements and Related Amendments to PCAOB Standards (PDF) September 14, 2011
- FIRCA Comment Letter to the SEC Regarding SEC's Staff Paper on the Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers: Exploring a Possible Method of Incorporation. (PDF) July 28, 2011
- Comment Letter to the SEC Regarding SEC's Staff Paper on the Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers: Exploring a Possible Method of Incorporation. (PDF) July 28, 2011
- Comment Letter to the SEC regarding SEC Staff Paper on the Work Plan for the Consideration of Incorporating International Financial Reporting Standards into the Financial Reporting System for U.S. Issuers. (PDF) July 22, 2011
- Joint Trade Association FASB/IASB Letter on Lease Accounting Standards (PDF) July 8, 2011
- Joint Trade Association FASB IASB Letter on Leases 05.26.11(PDF) May 26, 2011
- Comment letter to the FASB and IASB on Offsetting Fianancial Liabilities. (PDF) April 28, 2011
- FIRCA comment letter on Impairments. (PDF) April 1, 2011
- Comment letter to the Federal Reserve regarding the proposal on the definition of “predominantly engaged in financial activities” and “significant nonbank financial companies and bank holding companies.” (PDF) March 30, 2011
- FIRCA Comment Letter on Effective Dates and Transitions. (PDF) March 25, 2011
- FIRCA Comment Letter to IASB on Hedge Accounting (PDF) March 11, 2011
- Comment letter on FASB Discussion Paper and IASB Requests for Views on Effective Dates and Transitions. (PDF) February 2, 2011
- Comment letter on the Discussion Paper and Request for Views on Effective Dates and Transition Methods. (PDF) February 1, 2011
- Chamber FASB IASB Lease Comment Letter (PDF) December 15, 2010
- Joint Trade Association Letter to FASB and IASB on leases and exposure draft. (PDF) December 8, 2010
- Letter to the European Commission re: "Green Paper on Audit Policy: Lessons from the Crisis" (PDF) December 7, 2010
- Letter to G-20 participants re: Lease Accounting (PDF) October 21, 2010
- Comment letter to the SEC re: the IFRS WorkPlan (PDF) October 18, 2010
- Comment letter to SEC on the PCAOB proposed risk standards (PDF) October 13, 2010
- Joint Trade letter to FASB re: proposed revisions to FAS 5 (PDF) September 16, 2010
- Letter to the PCAOB regarding Proposed Auditing Standard Related to Confirmation and Related Amendments (PDF) September 13, 2010
- FIRCA letter to FASB re: Financial Instruments Project (PDF) August 31, 2010
- Letter to FASB re: Financial Instruments Project (PDF) August 30, 2010
- Letter to FASB on the proposal to revise FAS 5 (PDF) August 11, 2010
- Letter to FASB requesting extension on FAS 5 (PDF) August 3, 2010
- Letter to IFRS and FASB regarding concerns about the pace of accounting standards convergence projects (PDF) June 4, 2010
- Letter to the G20 regarding concerns about the pace of accounting standards convergence projects (PDF) June 4, 2010
- Letter to the PCAOB regarding standards for auditor-audit committee communications (PDF) May 28, 2010
- Comment Letter to the IASB on IAS 37 (PDF) May 17, 2010
- Letter to PCAOB on Proposed Auditing Standards (PDF) March 2, 2010
Letter to Chairman Garrett and Ranking Member Waters Supporting H.R. 2483, the “Whistleblower Improvement Act.” (PDF) December 13, 2011- Letter to Senators Toomey and Carper Supporting S. 1824, the “Private Company Flexibility and Growth Act”. (PDF) November 30, 2011
- Letter to Senators Tim Johnson and Richard Shelby Regarding hearing titled "Spurring Job Growth While Protecting Investors. (PDF) November 30, 2011
- Comment Letter to ISS Regarding 2012 Draft Policies (PDF) November 7, 2011
- Coalition Comment Letter to ISS Regarding Proposed 2012 Proxy Voting Policy on Political Spending. (PDF) November 7, 2011
- Letter to the SEC Regarding Companies Engaged in the Business of Acquiring Mortgages and Mortgage-Related Instruments. (PDF) November 7, 2011
- Letter to the SEC Regarding Treatment of Asset-Backed Issuers Under the Investment Company Act. (PDF) November 7, 2011
- Letter to the Members of the U.S. House of Representatives Supporting H.R. 1965, H.R. 2167, H.R. 2930, H.R. 2940. (PDF) October 31, 2011
- Letter to the Institutional Shareholder Services Requesting an Extension of the Open Comment Period. (PDF) October 27, 2011
- Letter to Senators Tester and Toomey Regarding the S. 1544 "Small Company Capital Formation Act of 2011". (PDF) September 28, 2011.
- Letter in support of H.R. 1965, H.R. 2167, H.R.2930, and H.R. 2940 – Small Business Capital Formation Bills. (PDF) September 20, 2011
- Letter to the U.S. Senate, Committee on Homeland Security and Government Affairs regarding S.1483, the “Incorporation Transparency and Law Enforcement Act”. (PDF) September 13,2011
- Letter to the House Committee on Financial Services Regarding the SEC Modernization Hearing. (PDF) September 13, 2011
- Letter to SEC requesting that the SEC monitors the acitivites of Glass-Lewis.
- Joint comment letter in Support of Proposed Protections for the Attorney-Client Relationship and Privileged Communications, Proposed Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934. (PDF) May 23, 2011.
- Comment Letter to the SEC Concept Release Proxy System. Office of Inspector General – Proxy-Voting Report (PDF) May 9, 2011
- Comment letter to the SEC, to supplement the December 17, 2010 letter on Proposed Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934 (PDF) February 15, 2011
- CCMC and the Chamber Institute for Legal Reform filed a comment letter with the CFTC on their proposed whistleblower rules (PDF) Feb. 6, 2011
- Comment Letter on Proposed Rules for Implementing the Proposed Rules for Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934. (PDF) December 17, 2010
- Joint Comment Letter with ILR on Proposed Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934. (PDF) December 17, 2010
- Joint Comment Letter on SEC Whistleblower Proposed Rules (PDF) December 7, 2010
- Suggested changes to the SEC Whistleblower Proposed Rules (PDF) December 7, 2010
- Letter to SEC on Concept Release on the U.S. Proxy System. (PDF) August 5, 2010
- Letter to SEC on the California Public Employees Retirement System Plan. (PDF) July 22, 2010
- Opposition Letter to the so-called “corporate governance” provisions, Title IX, Subtitle E (sections 951 through 959) and Subtitle G (sections 971 through 973) of the “Restoring American Financial Stability Act”. (PDF) June 15, 2010
- Joint Trades Letter to HFSC on Corporate Governance Bills for April 21 Hearings (PDF) April 20, 2010
- Letter to Senate on the Restoring American Financial Stability Act (PDF) April 13, 2010
- Multi Industry Letter to Senate Banking Committee on Corporate Governance Provisions in Regulatory Reform (PDF) February 16, 2009
- Comment Letter to SEC on Proposed Amendments to Rule 163(c) (PDF) January 27, 2010
- Additional Comment Letter to Chairman Shapiro on Proxy Access (PDF) January 19, 2010
- Joint Trades Letter to the SEC Regarding Regulatory Initiatives under the Dodd-Frank Act Title IX: Investor Protections and Improvements to the Regulation of Securities, Subtitle E Accountability and Executive Compensation. (PDF) January 19, 2012
- Comment Letter on Proposed Rules on Incentive-Based Compensation Arrangements. (PDF) July 13, 2011
- Comment Letter to the Financial Stability Board regarding Peer Review on Compensation Practices. (PDF) June 15, 2011
- Comment Letter to the Federal Reserve System on Incentive Based Compensation Arrangements. (PDF) May 31, 2011
- Comment Letter to the SEC on Incentive Based Compensation Arrangements. (PDF) May 31, 2011
- Comment Letter to the FDIC on Incentive Based Compensation Arrangements. (PDF) May 31, 2011
- Comment Letter to the Office of the Comptroller of the Currency on Incentive Based Compensation Arrangements. (PDF) May 31, 2011
- Comment Letter to the Office of Thrift Supervision on Incentive Based Compensation Arrangements. (PDF) May 31, 2011
- Joint Comment Letter to the SEC on Proposed Rules on Incentive-Based Compensation Arrangements. (PDF) May 25, 2011
- Joint Comment letter to the SEC regarding Incentive-Based Compensation Arrangements. (PDF) May 23, 2011
- Comment letter to the SEC regarding Rules on Listing Standards for Compensation Committees Release. (PDF) April 28, 2011
- Comment Letter on Proposed Rules on Listing Standards for Compensation Committees. (PDF) April 15, 2011
- Opposition letter to the U.S. House of Representative on the disclosure requirements in Section 953 – Pay for Performance – of HR 4173. (PDF) June 14, 2010
- Letter to Senate Oppossing Webb and Boxer Amendment "Tax Extenders Act of 2009" (PDF) March 4, 2010
- Letter to FDIC on Proposed Rulemaking on Executive Compensation (PDF) February 18, 2010
- Letter to House Financial Services Committee on Executive Compensation Hearing (PDF) January 21, 2010
- Joint Trade letter to Chairman Schapiro Regarding Money Market Funds. (PDF) January 20, 2012
- Letter to Chairman Schapiro Regarding Money Market Funds. (PDF) November 17, 2011
- Letter to the Members of the House Committee on Financial Services regarding Hearing on the "Oversight of the Mutual Fund Industry: Ensuring Market Stability and Investor Confidence (PDF) June 23, 2010
- Joint Comment Letter on on the President’s Working Group Report on Money Market Fund Reform. (PDF) January 10, 2011
- Joint Letter Secretary Geithner and Chairman Schapiro on Money Market Funds need for stable per-share value. (PDF) July 21, 2010
- Jones v. Harris Case Review (PDF) April 1, 2010
- Hill Letter Opposing amendment # 1931 offered by Senator Reed to H.R. 3606, the “Reopening American Capital Markets to Emerging Growth Companies Act of 2011. (PDF) March 21, 2012
- Hill Letter to the House Financial Services Commitee on H.R. 2308, H.R. 4014, and H.R. 3606. (PDF) February 15, 2012
- Hill Letter Regarding "“Examining the Impact of the Volcker Rule on Markets, Businesses, Investors, and Job Creation" hearing. (PDF) January 17, 2012
- Letter to the Federal Reserve, FDIC, SEC, OCC, and CFTC Regarding Prohibitions and Restrictions on Proprietary Trading and Certain Interests in and Relationships with, Hedge Funds and Private Equity Funds. (PDF) January 17, 2012
- Letter to the Members of Congress Regarding CCMC's New Report: U.S. Securities and Exchange Commission: a Roadmap for Transformational Reform. (PDF) December 13, 2011
- Comment Letter to the Federal Reserve, FDIC, SEC, and Office of the Comptroller of the Currency Regarding Volcker Rule Re-Proposal and Extension Notice. (PDF) November 17, 2011
- Letter to Senators Reed and Crapo Regarding Senate Committee on Banking, Housing, and Urban Affairs Subcommittee on Securities, Insurance and Investment hearing “Management and Structural Reforms at the SEC” . (PDF) November 15, 2011
- Letter to The Honorable Scott Garrett and The Honorable Maxine Waters Supporting H.R. 2308, the “SEC Regulatory Accountability Act”. (PDF) November 14, 2011
- Comment Letter to the Department of Treasury Regarding Post-Employment Restrictions for the Employees of the Department of Treasury. (PDF) November 8, 2011
- Letter to Chairman Bachus and Ranking Member Frank Supporting H.R. 2167, the “Private Company Flexibility and Growth Act,” H.R. 2930, the “Entrepreneur Access to Capital Act,” and H.R. 2940, the “Access to Capital for Job Creators Act.” (PDF) October 25, 2011
- Letter to Secretary Geithner Regarding Section 619 of the Dodd-Frank Act, the "Volcker Rule". (PDF) October 11, 2011
- Comment Letter to the SEC Regarding Retrospective Review of Existing Regulations. (PDF) October 6, 2011
- Letter to Congressman Posey Regarding H.R. 2568. (PDF) September 28, 2011
- Letter to Senator Rubio Regarding S. 1506. (PDF) September 28, 2011
- Letter to Senator Shelby Regarding "Financial Regulatory Responsibility Act of 2011". (PDF) September 15, 2011
- Letter Regarding the Hearing Entitled "Financial Management, Work Force and Operations at the SEC". (PDF) March 10, 2011.
- Letter Regarding the Hearing Entitled "Oversight of the Securities and Exchange Commission's Operations, Activities, Challenges and FY 2012 Budget Request" (PDF) March 10, 2011
- Letter to the Financial Stability Oversight Council on the Volcker Rule. (PDF) November 5, 2010
- Letter to U.S. Senate Opposing Dodd-Frank bill passage. (PDF) June 28, 2010
- Letter to SEC on Proposed Self-Regulatory Organization Rule Changes Adding Trading Pauses. (PDF) June 3, 2010
- Support for Sens. Carper and Corker to RAFSA which would maintain current law with respect to limits on state regulation of federally-chartered financial. (PDF) May 18, 2010
- Letter to Senate Opposing the Restoring American Financial Stability Act (PDF) March 22, 2010
- Letter to U.S. Senate in Support for Pryor amendment to S. 3217 that would clarify the definition of nonfinancial company in Title I of the bill. (PDF) May 18, 2010
- Letter to the Senate opposing the Restoring American Financial Stability Act (PDF) April 19, 2010
- Joint Comment Letter to the CFPB Regarding Qualified Mortgage. (PDF) April 27, 2012
- Comment Letter to the CFPB Regarding “Defining Larger Participants in Certain Consumer Financial Product and Service Markets". (PDF) April 17, 2012
- Comment Letter to the CFPB Regarding “Confidential Treatment of Privileged Information". (PDF) April 16, 2012
- Letter to the U.S. House of Representatives Supporting H.R. 4014, a bill to amend the Federal Deposit InsuranceAct with respect to information provided to the Bureau of Consumer Financial Protection. (PDF) March 22, 2012
- Letter to CFPB on Streamlining Inherited Regulations (PDF) March 5, 2012
- Small business sign-on letter to the Senate Banking Committee regarding small business provisions in Dodd-Frank (PDF) January 31, 2012
- Comment letter to CFPB with guidelines to help mitigate harmful impacts on consumers, small business, and the economy (PDF) January 31, 2012
- Comment Letter to the CFPB Regarding the Small Business Provisions of the Dodd-Frank Act (PDF) January 24, 2012
- Letter to the Senate Opposing the Nomination of Richard Cordray as Director of the CFPB (PDF) December 7, 2011
- Joint Comment Letter to the CFPB Regarding Notice of Modified Privacy Act System of Records. (PDF) December 5, 2011
- Comment Letter to the CFPB Regarding the Disclosure of Records and Information. (PDF) October 21, 2011
- Joint Comment Letter to the CFPB regarding “State Official Notification Rules". (PDF) September 26, 2011
- Joint Comment Letter to the CFPB Regarding Defining Larger Participants in Certain Consumer Fiancial Products and Services Markets. (PDF) August 15, 2011
- Key Vote Letter to all Members of the House in support of HR 1315, the CFPB reform bill.
- Comment Letter on the enforcement authority of the Consumer Financial Protection Bureau (CFPB) and FTC in order to provide clarity for both businesses and consumers. (PDF) June 16, 2011
- Joint Trade Assication Letter to the SEC regarding Rules Implementing Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act. (PDF) May 31, 2011
- Letter to Members of the House Committee on Financial Services regarding H.R.1121, H.R. 1315, and H.R. 1667. (PDF) May 11, 2011.
- Multi Industry Consumer Financial Protection Bureau to Secretary Geithner (PDF) February 28, 2011
- Comment letter on proposed Privacy Act system of Records to the Consumer Financial Bureau Implementation Team. (PDF) February 9, 2011
- Letter to Treasury on CFPA (PDF) March 26, 2010
- Multi-Industry Letter sent to Senate on CFPA (PDF) February 17, 2010
- Coalition for Derivatives End-Users Support Letter for H.R. 2682, H.R. 2779, and H.R. 2586 (PDF) March 23, 2012
- Coalition for Derivatives End-Users Support Letter for House Ag Mark-up (PDF) January 24, 2012
- Coalition for Derivatives End-Users Support Letter for House Financial Services Mark-up. (PDF) November 29, 2011
- Coalition for End-Users Letter to CFTC in support of H.R. 2779 regarding Core Principles and Other Requirements for Swap Execution Facilities (PDF) November 14, 2011
- Coalition for End-Users Letter to CFTC on proposed rules regarding swap transaction compliance and implementation schedule (PDF) November 4, 2011
- Coalition for Derivatives End-Users Letter to Senators Crapo and Johanns Supporting SA 814. (PDF) October 20, 2011
- Coalition for End-Users Comment Letter in support of H.R. 2682; the Grimm-Peters Business Risk Mitigation and Price Stabilization Act (PDF) October 11, 2011
- Coalition for End-Users Comment Letter in support of H.R. 2779; the Stivers-Fudge inter-affiliate swaps bill (PDF) October 11, 2011
- Coalition for End-Users Comment Letter in support of S. 1650; the Crapo-Johanns Dodd-Frank Improvement Act (PDF) October 11, 2011
- Coalition for End-Users Comment Letter on "Further Definition of 'Swap,' 'Security-Based Swap,' and 'Security-Based Swap Agreement;' Mixed Swaps; Security-Based Swap Agreement Recordkeeping." (PDF) July 22, 2011
- Coalition for End-Users Comment Letter on Margin and Capital Requirements for Covered Swap Entities. (PDF) July 11, 2011
- Coalition for End-Users Comment Letter on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Paticipants. (PDF) July 11, 2011
- Coalition for Derivatives End-Users Comment Letter on Proposed Rule Swap Data Recordkeeping and Reporting. (PDF) June 9, 2011
- Coalition for Derivatives End-User Comment Letter on Determination of Foreign Exchange Swaps and Forwards under the Commodity Exchange Act, Notice of Proposed Determination. (PDF) June 6, 2011
- Joint Trade Association Reopening and Extension of Comment Letter (76 FR 25274) (PDF) May 26, 2011
- Coalition for Derivatives End-Users Comment on Proposed Interpretive Order, Antidisruptive Practices Authority. (PDF) May 17, 2011
- Coalition for Derivatives End-Users Letter to House Financial Services Capital Markets Subcommittee regarding Support for H.R. 1610, Business Risk Mitigation and Price Stabilization Act of 2011 (PDF) May 2, 2011
- Comment Letter on CFTC’s Rule 4.5 relating to commodity pool operator. (PDF) April 12, 2011
- Coalition for Derivatives End-Users Comment Letter on Swap Trading Relationship Documentation Requirements for Swap. (PDF) April 11, 2011
- Trade Assoication Letter Requesting to Extend Derivatives Rules Deadline. (PDF) April 8, 2011
- Letter from Sens. Johnson and Stabenow and Cong. Lucas and Bachus to regulators urging them not to impose margin on end-user transactions (PDF) April 6, 2011
- Comment letter to the Commodity Futures Trading Commission on position limits for derivatives (PDF) March 28, 2011
- Coalition for Derivatives End-Users letter on Swap Execution Facilities (PDF) March 8, 2011
- Derivatives End-User's Coalition Support for Chatham regarding reporting and recordkeeping. (PDF) February 25, 2011
- Coalition for Derivatives End-Users Comment Letter to the CFTC Regarding Entity Definitions. (PDF) February 22,2011
- Chatham Financial's comment letter on the swap data recordkeeping and reporting NPRM. (PDF) February 7, 2011
- Derivatives End-User’s Coalition Comment Letter on The End-User Exemption (PDF) February 22, 2011
- Derivatives End-User’s Coalition Comment Letter on Entity Definitions (PDF) February 22, 2011
- Derivatives End-User’s Coalition Comment Letter on Real-Time Public Reporting of Swap Transaction Data. (PDF) February 7, 2011
- Coalition for Derivatives End-Users letter asking Senators to sign the Johanns letter to the CFTC requesting that Congressional intent be fulfilled and that an end-user exemption be implemented. (PDF) February 4, 2011
- Coalition for Derivatives End-Users Letter Regarding the Derivatives Title of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. (PDF) January 31, 2011
- Letter to the CFTC by the End-Users Coalition regarding the protection of cleared swaps customers (PDF) January 18, 2011
- Letter to CFTC by the End-Users Coalition regarding the process to determine mandatory clearing of swaps. (PDF) January 3, 2011
- Letter to Senate from Coalition for Derivatives End-Users on OTC Derivatives (PDF) February 3, 2010
- Letter to Chairman Gensler on Swap Execution Facilities for Derivatives (PDF) January 15, 2010
- Comment Letter to the Federal Reserve regarding Enhanced Prudential Standards (PDF) April 30, 2012
- Comment Letter to FSOC Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies. (PDF) March 8, 2012
- Coalition Comment Letter to FSOC Requesting a Public Hearing (PDF) March 8, 2012
- Letter to the FRB Requesting that the FRB extend the Enhanced Prudential Standards and Early Remediation Requirements for Covered Companies Comment Period. (PDF) January 30, 2012
- Comment Letter to FSOC Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies. (PDF) December 19, 2011
- Comment Letter to the Office of the Comptroller of the Currency Regarding Proposed Rules to Implement the Credit Risk Retention Requirements of Section 15G of the Securities Exchange Act of 1934, as Added by Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. (PDF) August 1, 2011
- Letter to the House Committee on Financial Services Regarding Hearing Entitled: Annual Report of the Financial Stability Oversight Council. (PDF) October 5, 2011
- Comment Letter to the Board of Governors of the Federal Reserve System Regarding Proposed Rules to Implement the Credit Risk Retention Requirements of Section 15G of the Securities Exchange Act of 1934, as Added by Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. (PDF) August 1, 2011
- Comment Letter to the Federal Deposit Insurance Corporation Regarding Proposed Rules to Implement the Credit Risk Retention Requirements of Section 15G of the Securities Exchange Act of 1934, as Added by Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. (PDF) August 1, 2011
- Comment Letter to the Securities Exchange Commission Regarding Proposed Rules to Implement the Credit Risk Retention Requirements of Section 15G of the Securities Exchange Act of 1934, as Added by Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. (PDF) August 1, 2011
- Comment Letter to the Federal Housing Finance Agency Regarding Proposed Rules to Implement the Credit Risk Retention Requirements of Section 15G of the Securities Exchange Act of 1934, as Added by Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. (PDF) August 1, 2011
- Comment Letter to the Department of Housing and Urban Development Regarding Proposed Rules to Implement the Credit Risk Retention Requirements of Section 15G of the Securities Exchange Act of 1934, as Added by Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. (PDF) August 1, 2011
- Comment Letter to the Federal Reserve regarding Global Systemically Important Financial Institutions. (PDF) June 14, 2011
- Comment letter on resolution plans and credit exposure reports required. (PDF) June 10, 2011
- Letter to Members of the Senate Committee on Banking, Housing, and Urban Affairs regarding Oversight of Dodd-Frank Implementation. (PDF) May 11, 2011
- Comment Letter to the SEC on Reporting by Investment Advisers to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF. (PDF) April 12, 2011
- Comment letter to the Financial Stability Oversight Council on Proposed Rulemaking Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies. (PDF) February 25, 2011
- Comment Letter on Proposed Rulemaking Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies (PDF) November 5, 2010
- Main Street Industry Alliance Letter on Systemic Risk and Resolution Authority (PDF) April 1, 2010
- Letter to Senate Banking Committee on Monitoring Systemic Risk (PDF) March 3, 2010
Volcker Rule
- Comment Letter to the CFTC Regarding Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships With, Hedge Funds and Covered Funds. (PDF) April 16, 2012
- Hill Letter to Senate Committee on Banking, Housing and Urban Affairs Regarding the Volcker Rule. (PDF) February 29, 2012
- Hill Letter to Members of the House Committee on Financial Services Regarding the Volcker Rule. (PDF) February 29, 2012
- Coalition Comment Letter Regarding Prohibitions and Restrictions on Proprietary Trading and Certain Interests.(PDF) February 21, 2012
- Coalition Comment Letter to the SEC, FDIC, OCC, CFTC, and Federal Reserve Regarding Prohibitions and Restrictions on Proprietary Trading and Certain Interests in and Relationships With, Hedge Funds and Private Equity Funds. (PDF) February 14, 2012
- Comment Letter to the SEC, FDIC, OCC, and Federal Reserve Regarding Prohibitions and Restrictions on Proprietary Trading and Certain Interests in and Relationships With, Hedge Funds and Private Equity Funds (PDF) February 13, 2012
Capital Formation
- Letter to U.S. Senate Supporting supports H.R. 3606, the “Reopening American Capital Markets to Emerging Growth Companies Act of 2011”. (PDF) March 20, 2012
- Hill Letter Regarding “Jumpstart our Business Startups Act” (JOBS Act). (PDF) March 6, 2012
- Letter Regarding H.R. 1070, the "Small Company Capital Formation Act of 2011," H.R. 1062, the "Burdensome Data Collection Relief Act," H.R. 1082, the "Small Business Capital Access and Job. (PDF) June 20, 2011
- Letter to the Subcommittee on International Monetary Policy and Trade Regarding Conflict Minerals. (PDF) May 9, 2012
- Letter to Secretary Geithner Regarding Guidance on Reporting Interest Paid to Nonresident Aliens. (PDF) April 16, 2012
- Letter to the NY Assembly reagarding the Martin Act (PDF) March 14, 2012
- Letter to the SEC on Application of Adviser Act Rule (PDF) March 6, 2012
- Joint Comment Letter to the FIO on the Report to Congress on How to Modernize and Improve the System of Insurance Regulation in the U.S. (PDF) December 16, 2011
- Joint Comment Letter to SEC Regarding Study to Determine the Extent to Which Private Rights of Action Under the Antifraud Provisions of the Securities Exchange Act of 1934. (PDF) December 16, 2011
- Comment Letter to the SEC, FDIC, OCC, and Federal Reserve Regarding Prohibitions and Restrictions on Proprietary Trading and Certain Interests in and Relationships With, Hedge Funds and Private Equity Funds. (PDF) December 15, 2011
- Comment Letter to the SEC Regarding Proposed Rules on Conflict Minerals. (PDF) November 29, 2011
- Joint Comment Letter to the Financial Crimes Enforcement Network Regarding A Request for FBAR Relief For Multinational Corporate Employees. (PDF) November 4, 2011
- Letter to the Senate Committee on Banking, Housing, and Urban Affairs Regarding Hearing Entitled "Financial Stability Oversight Council Annual Report to Congress" (PDF) October 3, 2011
- Coalition letter to Secretary Geithner opposing European Union proposals for a Financial Transaction Tax. (PDF) September 22, 2011
- Comment Letter to the Department of Labor Regarding the Definition of Term "Fiduciary". (PDF) August 4, 2011
- Letter to all Members of Congress Regarding CCMC Report: U.S. Capital Markets Competitiveness: the Unfinished Agenda. (PDF) July 19, 2011
- Comment Letter to the SEC Regarding Conflict Minerals. (PDF) July 18, 2011
- Letter to the U.S. Senate supporting Senator Portman's Amendment 417 to S.782, the "Economic Development Revitalization Act of 2011" (PDF) June 14, 2011
- Letter Regarding the Release of Sources of Capital and Economic Growth: Interconnected and Diverse Markets Driving U.S. Competitiveness (PDF) March 29, 2011
- Letter to the Independent Agencies Requesting they Comply with Executive Oder 13563- Fed (PDF) February 1, 2011
- Letter to the Independent Agencies Requesting they Comply with Executive Oder 13563- FDIC (PDF) February 1, 2011
- Comment Letter to the SEC on Proposed Rules on Conflict Minerals. (PDF) February 28, 2011
- Letter to Federal Reserve regarding proposed amendments to Regulation Z, Truth in Lending Act. (PDF) December 22, 2010
- Comment letter to the FDIC regarding Liquidation Authority. (PDF) November 18, 2010
- Letter on provision of the Telemarketing Sales Rule notice of proposed rulemaking on debt relief. (PDF) July 20, 2010
- Joint Letter the Leaders of the G-20 regarding the International Financial Transaction Tax. (PDF) June 9, 2010
- Comment Letter on Concept Release on Equity Market Structure (PDF) April 21, 2010
- Joint Letter Opposing Changes to Regulation D (PDF) April 9, 2010
- Joint Letter to House Ways and Means Committee Opposing Bank Tax (PDF) March 30, 2010
- Letter urging the Senate to Approve the Nomination of Ben Bernanke for a Second Term as Chairman of the Federal Reserve (PDF) January 22, 2010
- Letter to Treasury Opposing Potential Bank Levy Tax (PDF) January 13, 2010
Regulatory Reform
- Comment Letter to the CFTC Regarding Part 4 Harmonization of Compliance Obligations for Registered Investment Companies Required to Register as Commodity Pool Operators. (PDF) April 24, 2012
- Letter to the Subcommittee on Capital Markets and Government Sponsored Enterprises Regarding Oversight of the U.S. Securities and Exchange Commission Hearing. (PDF) April 24, 2012
- Letter to the Members of Congress Regarding Financial Regulatory Reform: 2012 Report Card. (PDF) March 27, 2012
- Letter to FINRA Regarding Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies. (PDF) April 11. 2012