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.