Date: June 3, 2016

Issue: Federal Reserve

To: The Federal  Reserve

Filing Type: Regulatory

Description: The Federal Reserve has taken important steps with its proposed rule to set limits on the credit exposure of domestic or foreign bank holding companies to unaffiliated counterparties (the “Proposed Rule”) to make this reproposal more workable, especially with respect to its treatment of derivatives and raising of exposure limit thresholds. However, despite these improvements, we again find a lack of consideration for the impact of the Proposed Rule on ability of financial institutions to provide loans to businesses of all sizes.

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