The U.S. Chamber of Commerce (“the Chamber”) writes in response to the advance notice of proposed rulemaking (“ANPR”) from the Board of Governors of the Federal Reserve System (“Board”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, “the Agencies”) on Resolution-Related Resource Requirements for Large Banking Organizations.
The Chamber supports a stable financial system that can meet the financing needs of
American businesses. As a result of the reforms instituted after the global financial crisis of
2007-2008, the banking system has improved its ability to weather economic downturns. U.S.
banks now hold significantly more capital to ensure they withstand losses, and liquidity
requirements ensure banks can meet the demands of a future crisis.
Since being confirmed by the Senate in July 2022, Federal Reserve Vice Chair for
Supervision Michael Barr has repeatedly stated that the Board is conducting a holistic review
before moving forward with any changes to capital requirements. At a September 7, 2022 speech
at the Brookings Institution, Governor Barr stated of the post-financial crisis reforms, “many
gains have been made from this process. While recognizing these gains, we need to continue to
analyze whether firms are taking all appropriate steps to limit the costs to society of their
potential failure.”