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.