Archives for Systemic Risk

Letter to the Federal Reserve regarding Enhanced Prudential Standards for Systemically Important Insurance Companies (8/17/16)

Date: August 17, 2016

Issue: Systemic Risk; Insurance

To: Federal Reserve

Filing Type: Regulatory

Description: The Chamber emphasizes the importance of designing properly calibrated enhanced prudential standards for SIICs that are appropriate for the business of insurance and do not damage the capital markets. The Dodd-Frank Act requires the Federal Reserve to properly recognize the differences among bank holding companies and other nonbank financial companies designated as SIFIs by the FSOC. We believe that several of the requirements listed in the Proposal, particularly with respect to liquidity risk management, fail to make this distinction.

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Chamber Comment letter on OFR Study (10/3/2013)

Date: October 30, 2013

Issue:  Office of Financial Research 

To: Secretary, Securities and Exchange Commission

Filing Type: Regulatory

Description: CCMC submitted a comment letter to the SEC outlining concerns with the Office of Financial Research’s (OFR) “Report on Asset Management and Financial Stability.”  We were especially disappointed that the OFR, which Congress set up to review the best available data from all regulators, failed to even solicit available data from the SEC or asset managers and yet reached sweeping conclusions about the industry.  Our letter was submitted to the SEC since the Commission requested comments but OFR itself did not.  The letter requests that the report be withdrawn and not utilized as part the FSOC’s review of the role of asset management firms in the consideration of systemic risk. 

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H.R. 1341 Financial Competitive Act

Date: April 11, 2013

Issue:  Financial Stability Oversight Council

To: The Honorable Stephen Lee Fincher

Filing Type: Congressional

Description: The Chamber sent a letter to in support of H.R. 1341, the “Financial Competitive Act of 2013,” which would help ensure that end-users continue to have efficient affordable options in the market for risk mitigation.

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Mitigating Systemic Risk Through Wall Street Reforms

Date: July 9, 2013

Issue: Systemic Risk

To: Members of the Senate Committee on Banking, Housing, and Urban Affairs

Filing TypeCongressional Letter

Description: CCMC sent a letter, highlighting the results of How Main Street Businesses Use Financial Services Survey, to the members of the U.S. House of Representatives in advance of the Senate Banking Committee’s hearing entitled Mitigating Systemic Risk Through Wall Street Reforms.

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Enhanced Prudential Standards and Early Remediation Requirements for Foreign Banking Organizations and Foreign Nonbank Financial Companies

Date: April 30, 2013

Issue: Systemic Risk

To: Board of Governors of the Federal Reserve System

Filing Type: Regulatory

Description: The CCMC believes that the current proposal being considered by the Federal Reserve to enhance prudential standards and set early remediation requirements for foreign banks and non-bank financials—and potential overseas retaliatory actions—will place American businesses at a competitive disadvantage. Specifically, the Chamber is concerned that the proposal:

  • Fails to consider impacts on Main Street businesses and the economy;
  • Lacks appropriate cost-benefit analysis;
  • Subjects FBOs to disparate treatment by setting up a ring-fence approach that requires the establishment of an Intermediate Holding Company and applies discriminatory treatment to IHCs; and
  • Places U.S.-owned subsidiaries operating abroad at risk of retaliatory disparate treatment as foreign governments may seek to impose reciprocal requirements on U.S. banks operating in their countries.

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