Date: August, 4 2016
Issue: Systemic Risk and Capital Standards
To: Mr. Thomas J. Curry (Office of the Comptroller of the Currency), Mr. Robert deV. Frierson (Federal Reserve), Mr. Robert E. Feldman (FDIC),
Filing Type: Regulatory
Description: The U.S. Chamber of Commerce has highlighted several concerns with the Proposed Rule and its impact on the capital markets, particularly with respect to continued access to cost-effective risk mitigation techniques and raising capital. In particular, we believe that the Federal banking regulators must take significant steps to make the NSFR more risk-sensitive, while also eliminating requirements such as the 20% counterparty payables “add-on” that will essentially serve as a tax on nonfinancial corporate trades.