Regulatory Comment Letters

Joint-Trade Letter on Proposed Cyber Requirements from the New York Division of Financial Services

Comparison of U.S. and E.U. Proposals Establishing a Net Stable Funding Ratio (NSFR)

FSR along with six other financial trade associations note differences between the NSFR proposals of the Federal Reserve and the European Union. Notably many of the elements within the E.U. NSFR proposal require lower funding levels than what would be required under the rules proposed by the Federal Reserve.

Joint-Trade Comment on CFTC Cross-Border Proposal

FSR and six other financial trade associations express their concern with a proposal by the Commodity Futures Trading Commission (CFTC) to register and regulate entities defined as “Foreign Consolidated Subsidiaries.” As the letter notes, these entities are already subject to the prudential rules of the foreign jurisdiction in which they...

Letter to FDIC on Proposed Mandatory Stay Requirements for Certain QFCs

Shortened Settlement Cycle for Securities Transactions

FSR supports efforts by the Securities and Exchange Commission to reduce the time that securities transactions are settled from three to two days. The proposed change will have a positive impact on systemic risk. FSR does note, however, that the proposed changes will also have impacts on other SEC settlement rules and asks that the SEC allow some...