Regulatory Comment Letters

Letter to FINRA on Mitigating Financial Exploitation

FSR expresses its support for a proposal by FINRA that would allow broker-dealers to withhold distributions from the account of vulnerable adults when there is reasonable evidence of financial exploitation. FSR believes covered firms should be given twelve months to conform to the new standards, and that certain clarifications should be added to...

Amendments to Federal Reserve Capital Planning and Stress Testing Rules

FSR supports the Federal Reserve’s proposal to no longer use qualitative criteria as the basis for objecting the annual capital plans of so-called “large and noncomplex” institutions. FSR members, however, do request that the Federal Reserve provide more information on the supervisory processes and documentation requirements for assessing...

FTC Letter on Safeguarding Consumer Information

FSR/BITS supports the continuation of the FTC’s rules on safeguarding information. FSR also believes that the FTC should correlate its rules with the NIST Cybersecurity Framework, and that further expansion of the rule over financial activities that are currently not covered by the FTC is unwarranted, considering the information protection...

Letter to CFPB on Amendments Related to Information Disclosures

Joint-Trade Letter to OCC on Mandatory Stay Requirement for Certain Qualified Financial Contracts