Date: February 2, 2015
Issue: Capital Standards
To: Financial Stability Board
Filing Type: International
Description: The GRGI believes that a balanced approach to capital, leverage and liquidity requirements is a pro-growth means of addressing over-leveraging and providing stability in a risk-based free enterprise system. We have expressed concerns with how leverage ratio, liquidity coverage ratio and net stable funding ratios meet this goal. We have more serious concerns with the TLAC proposal as we believe that it has the potential to deprive businesses of the resources needed to grow as well as drive up the costs of capital formation for market participants.