Date: September 11, 2014
Issue: Systemic Risk and Capital Standards
To: Board of Governors of the Federal Reserve System
Filing Type: Regulatory
Description: CCMC is concerned that the Proposal fails to take into consideration impacts on Main Street businesses, may deprive covered institutions of flexibility, adversely impact business decisions through a rigid regulatory approach and harm independent risk analysis. The CCMC believes that the unintended consequences of the Proposal may undermine financial stability, foster short-termism, and cause distortions in lending and capital formation that will impede economic growth thereby preventing the Board of Governors of the Federal Reserve (“Federal Reserve”) from fulfilling its mandates under the Full Employment and Balanced Growth Act (“Humphrey-Hawkins Act”).