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. 

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