Archives for SIFI

Letter to the Federal Reserve regarding Enhanced Prudential Standards for Systemically Important Insurance Companies (8/17/16)

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.

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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 FSB on Risk Culture (1/31/14)

Date: January 31, 2014

Issue: Capital Formation

To: Financial Stability Board

Filing Type: Regulatory Reform

Description: The Chamber’s Global Risk and Governance Initiative (GRGI) submitted a letter to the Financial Stability Board expressing concerns that its Risk Culture paper may create subjective guidelines that are redundant to, or in conflict with, the legal and regulatory provisions for systemically important financial institutions.

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Enhanced Prudential Standards and Early Remediation Requirements for Foreign Banking Organizations and Foreign Nonbank Financial Companies

Date: April 30, 2013

Issue: Systemic Risk

To: Board of Governors of the Federal Reserve System

Filing Type: Regulatory

Description: The CCMC believes that the current proposal being considered by the Federal Reserve to enhance prudential standards and set early remediation requirements for foreign banks and non-bank financials—and potential overseas retaliatory actions—will place American businesses at a competitive disadvantage. Specifically, the Chamber is concerned that the proposal:

  • Fails to consider impacts on Main Street businesses and the economy;
  • Lacks appropriate cost-benefit analysis;
  • Subjects FBOs to disparate treatment by setting up a ring-fence approach that requires the establishment of an Intermediate Holding Company and applies discriminatory treatment to IHCs; and
  • Places U.S.-owned subsidiaries operating abroad at risk of retaliatory disparate treatment as foreign governments may seek to impose reciprocal requirements on U.S. banks operating in their countries.

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