Date: January 31, 2014
Issue: Capital Standards
To: Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and the Federal Reserve
Filing Type: Regulatory
Description: We are concerned that applying a 100% outflow amount to undrawn credit commitments under bank customer securitization credit facilities could impact the availability or pricing of these facilities, thus curtailing our ability to provide cost effective financing to our customers and negatively impacting our ability to diversify the funding of our daily business, invest in new growth initiatives and create jobs.