Date: March 7, 2016
Issue: Federal Reserve
To: The Honorable Janet Yellen, Chair, Board of Governors of the Federal Reserve System
Filing Type: Regulatory
Description: The Chamber believes the current TLAC proposal will raise the cost of capital for businesses and divert working capital out of the markets, depriving businesses of the resources to grow and create jobs. To ignore these legitimate concerns raised in the recent correspondence submitted by five financial industry groups , the Federal Reserve could run afoul of the legal requirements to draft regulations as required under the Administrative Procedures Act (“APA”) and the Riegle Community Development and Regulatory Improvement Act (“Riegle Act”).