Regulatory Comment Letters

RoundDon’t Overhaul Regulatory Capital Framework without Due Diligence

In a joint-trade comment letter, submitted to regulators today, The Financial Services Roundtable recommended that regulatory agencies withdraw their Standardized Approach proposal regarding the Basel III regulatory capital framework, which deviates significantly from the standardized approach agreed to by the Basel Committee, and conduct an...

Letter re: Non-Banks and Dodd‐Frank Section 165 &166, 4/30/12

The Financial Services Roundtable (“The Roundtable”) and the Securities Industry and Financial Markets Association (“SIFMA”) welcome the opportunity to provide the Board of Governors of the Federal Reserve System (the “Board”) with comments on the proposed rules (the “Proposed Rules”) implementing section 165 and section 166 of the...

Letter re: Enhanced Prudential Standards & Early Remediation Regulations under Dodd‐Frank 165/166, 4/27/12

The Clearing House Association L.L.C. (“The Clearing House”), the American Bankers Association (the “ABA”), the Financial Services Forum (the “Forum”), The Financial Services Roundtable (“The Roundtable”) and the Securities Industry and Financial Markets Association (“SIFMA”) and, together with The Clearing House, the ABA, The...