Date: September 26, 2013
Issue: Systemic Risk and Capital Standards
To: Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency, Securities and Exchange Commission, and Commodity Futures Trading Commission
Filing Type: Regulatory
Description: The CCMC express concerns regarding the short time period for which comments may be filed on the revised proposal regarding credit risk retention published in the Federal Register on September 20, 2013 (“Revised Proposal”).1 The comment period, following the publication in the Federal Register, is only 37 days long, which is wholly insufficient for a rule that is over 120 pages long and that asks over 100 questions and many more sub-questions.