Date: February 2, 2015
Issue: Corporate Governance
To: Board of Governors of the Federal Reserve System
Filing Type: Regulatory
Description: The CCMC believes that the proposal in its current form is flawed because it is not appropriately tailored to fit the business model of GECC. These flaws are centered on the failure of the Federal Reserve to perform an economic analysis as required under the Riegle Act to identify impacts on the economic and potentially harmful consequences of the proposal and fails to take into account the impacts of the proposal upon Main Street businesses and the customers of GE who use GECC as a financing arm.