Regulatory Comment Letters

NIST Cybersecurity Framework Version 2.0

Request for the Release of FR Y-14 Technical Instructions

In reaction to an earlier request from the industry, the Federal Reserve delayed the effective date of certain changes to its FR Y-14 information reporting forms until June 30, 2016. Unfortunately, the Federal Reserve has not yet released the technical instructions that are associated with these changes, which prevents banking institutions from...

Response to CFTC Preliminary Report on the Swap Dealer De Minimis Exception

FSR urged the CFTC maintain the current swap dealer de minimis threshold to allow the CFTC more time to collect better data from various swap data repositories (“SDR”). FSR noted that lowering the limit would have substantial and unnecessary negative effective on mid-sized banks and other financial institutions that offer swaps on a...

Projected Costs of FinCEN Proposal on Customer Due Diligence

IAIS Letter on Systemic Risk Assessment Methodology

FSR filed comments with the International Association of Insurance Supervisors (IAIS) urging them to make changes to their proposed formula for determining how insurance companies are classified as Global Systemically Important Insurers (G-SIIs). FSR urges the IAIS to lower the current G-SII framework’s emphasis on measuring whether an insurer...