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.