Date: January 5, 2017
Issue: Capital Requirements / Commodities
To: Board of Governors of the Federal Reserve System
Filing Type: Comment Letter
Description: The letter expresses CCMC's significant disappointment with the Federal Reserve’s intention to impose new risk-based capital requirements on certain commodities activities of financial holding companies and their merchant banking investments.The proposal will have a deleterious effect upon growth and stability by creating barriers to traditional means of business financing and capital formation.
Date: August 17, 2016
Issue: Systemic Risk; Insurance
To: Federal Reserve
Filing Type: Regulatory
Description: The Chamber emphasizes the importance of designing properly calibrated enhanced prudential standards for SIICs that are appropriate for the business of insurance and do not damage the capital markets. The Dodd-Frank Act requires the Federal Reserve to properly recognize the differences among bank holding companies and other nonbank financial companies designated as SIFIs by the FSOC. We believe that several of the requirements listed in the Proposal, particularly with respect to liquidity risk management, fail to make this distinction.