Date: April 1, 2014
To: Robert de V. Frierson, Secretary, Board of Governors of the Federal Reserve
Filing Type: Regulatory
Description: The CCMC believes that the proposed capital surcharges on U.S. global
systemically important banking organizations (“GSIB”) could disrupt the balance
between financial stability and reasonable risk taking. This could harm the ability of businesses to access the capital and liquidity needed to grow and operate.
Additionally, because American financial institutions are subject to the Volcker Rule
and tougher Basel III rules than their international counterparts, the proposed GSIB
surcharges could place the U.S. financial system—and by extension our economy—at
a competitive disadvantage. Accordingly, we reiterate our request, first made in 2011,
for a legally mandated study to be conducted on the impact of proposed GSIB
surcharges upon the financial system, Main Street businesses, and economy to
ascertain potential negative consequences before these proposals are implemented.