Archives for FDIC

Letter to the Fed, FDIC, and OCC regarding Enhanced Cyber Risk Management Standards (1/18/17)

Date: January 18, 2017

Issue: Cyber

To: Federal Reserve; Federal Deposit Insurance Corporation; and Office of the Comptroller of the Currency

Filing Type: Comment Letter

Description: This letter is the Chamber's response to the Agencies' request for public comment regarding their joint advance notice of proposed rulemaking on “Enhanced Cyber Risk Management Standards.” American financial institutions and related entities are well aware of the substantial risks that cyber threats pose to the financial system. To mitigate these risks, they have invested heavily in developing cyber risk management programs, supported by substantial technological and personnel investments. The Agencies should not attempt to impose prescriptive requirements, but support industry efforts to enhance financial sector cybersecurity. The Chamber is urging policymakers to help agencies harmonize existing regulations with the NIST Cybersecurity Framework.

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Letter to Fed, FDIC, and OCC on Liquidity Coverage Ratio (1/31/14)

Date: January 31, 2014

Issue: Regulatory Reform

To: Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency

Filing Type: Regulatory

Description: CCMC submitted a comment letter to banking regulators addressing corporate treasurers' concerns with respect to the liquidity coverage ratio proposal issued by the regulators late last year. Applying a 100% outflow amount to undrawn credit commitments under bank customer securitization credit facilities could result in increased pricing of these facilities or reduce the availability of these facilities.

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Letter to Federal Reserve, FDIC, SEC, OCC, CFTC Regarding Volcker Rule Re-proposal (11/7/2013)

Date: November 7, 2013

Issue: Volcker

To:  Federal Reserve, FDIC, SEC, OCC, CFTC

Filing Type: Regulatory 

Description: CCMC summited a detailed letter to the agencies that are working on the Volcker Rule, requesting that instead of finalizing the Rule by year end, regulators should repropose the rule.  As previous comment letters articulated, we believe that the proposal will impede the ability and increase the cost of non-financial businesses to raise capital and manage risk and we don’t see how these concerns could be addressed by any final rule.  In addition, we believe that before the Volcker Rule is finalized companies should have the opportunity to comment on what must certainly be substantially altered from the original proposal.

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Letter to Federal Reserve, FDIC, OCC, and SEC on the Volcker Rule (9/25/2013)

Date: September 25, 2013

Issue:  Volcker Rule

To: Federal Reserve, FDIC, OCC, SEC, and CFTC

Filing Type: Regulatory

Description:  The CCMC respectfully requests that the additional comments be considered as work continues on final Volcker Rule regulations. Our comments reflect concerns about developments that have arisen since the comment period ended on the Volcker Rule. These developments were not foreseeable prior to this deadline and they materially enhance the scope and force of concerns the CCMC previously raised about the Volcker Rule Proposal.

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Letter to Federal Reserve, FDIC, and OCC regarding proposed leverage ratio rules (9/23/2013)

Date: September 23, 2013

Issue:  Accounting

To: Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency

Filing Type: Regulatory

Description:  The CCMC is concerned that the proposed leverage ratio rules are premature. The Bank for International Settlements (“BIS”) has issued for comment a discussion paper on The Regulatory Framework: Balancing Risk Sensitivity, Simplicity and Comparability (“Basel III capital simplification paper”) in an effort to reduce the complexity and opaqueness of the Basel III capital agreements (Basel III”). Furthermore, the Federal Reserve has not yet completed the final promulgation of the rules implementing section 165 of the Dodd Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). The proposed leverage ratios are also creating a divergence from international standards. The Chamber also wishes to express concerns that the proposed leverage ratio rules may adversely impact the ability of businesses to attractcapital harming their ability to grow and create jobs.

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