Date: February 11, 2016
Issue: Systemic Risk and Capital Standards
To: Mr. Robert de V. Frierson, Secretary, Board of Governors of the Federal Reserve
Filing Type: Regulatory
Description: We have highlighted several concerns with proposed TLAC rule, ranging from what we consider to be excessive capital requirements to the restrictive nature of how GSIBs may comply with their obligations under the proposed rule. These concerns are significant and, if not addressed, will sideline productive capital and limit the ability of Main Street business to grow and prosper.