Date: September 6, 2016
Issue: Systemic Risk and Capital Standards
To: Brent J. Fields, Secretary
Filing Type: Regulatory
Description: The CCMC agrees with the spirit of the Proposed Rule, but we have strong concerns relating to its extension of liability through Section 206(4)’s anti-fraud provisions. We also believe that business continuity plans should remain confidential and not filed or publically disclosed, especially given that market participants and the Commission will have access to this information. Finally, the transition plan requirement should be narrowly tailored in light of the Proposal’s requirements for business continuity plan.