Date: April 30, 2013

Issue: Systemic Risk

To: Board of Governors of the Federal Reserve System

Filing Type: Regulatory

Description: The CCMC believes that the current proposal being considered by the Federal Reserve to enhance prudential standards and set early remediation requirements for foreign banks and non-bank financials—and potential overseas retaliatory actions—will place American businesses at a competitive disadvantage. Specifically, the Chamber is concerned that the proposal:

  • Fails to consider impacts on Main Street businesses and the economy;
  • Lacks appropriate cost-benefit analysis;
  • Subjects FBOs to disparate treatment by setting up a ring-fence approach that requires the establishment of an Intermediate Holding Company and applies discriminatory treatment to IHCs; and
  • Places U.S.-owned subsidiaries operating abroad at risk of retaliatory disparate treatment as foreign governments may seek to impose reciprocal requirements on U.S. banks operating in their countries.

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