Date: August 5, 2016
Issue: Systemic Risk and Capital Standards
To: Mr. Thomas J. Curry (Office of the Comptroller of the Currency), Mr. Robert deV. Frierson (Federal Reserve), Mr. Robert E. Feldman (FDIC),
Filing Type: Regulatory
Description: The Coalition for Derivatives End-Users ask that the Agencies, in finalizing the Proposed NSFR, provide exemptive relief for corporate end-users’ derivatives transactions so that beneficial hedging activities are not discouraged. Such relief would encourage economic growth and jobs creation, promote a liquid marketplace, align with congressional intent and foster sound and prudent financial regulation. Implementation of the Proposed NSFR would likely increase costs borne by the end-user in the form of higher transaction fees, less favorable terms and more collateral requirements. The potential decrease in dealer participation, coupled with additional funding costs borne by the end-user, would hinder end-users’ abilities to effectively hedge and reduce business risks.