Date: September 19, 2016

Issue: Federal Reserve

To: Scott Alvarez, General Counsel, Board of Governors of the Federal Reserve

Filing Type: Regulatory

Description: The Federal Reserve’s Section 620 Report was undertaken through a fatally flawed process that did not consider stakeholder input, the impact of its recommendations on businesses that rely on the merchant banking authority and commodities activities of financial holding companies, and by circumventing any opportunity for notice and comment by issuing recommendations without thorough analysis as final policy judgments.

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