Regulatory Comment Letters

Industry Response to Federal Reserve Debit-Card Issuer Survey

The letter (signed by eight trade associations) applauds certain changes the Federal Reserve has made to its bi-annual survey on debit card interchange costs, and makes further recommendations for improvement. The major recommendations include (1) finalize the elimination of survey questions that require a breakdown between fixed and variable...

Federal Reserve Changes to the Proposed FR Y-14 A Forms

FSR asks for clarifications concerning certain FR Y-14 schedules, including the timing of certain guidance on syndicated pipeline reporting and whether some the additionally proposed reporting schedules must only be filed by larger reporting institutions. FSR also reiterates its request that the Federal Reserve increase the amount of time between...

SEC Proposal on Order Handling Information

FSR supports efforts by the SEC to increase information reporting on how orders by institutional investors are handled. The value of the information provided under the proposal, however, would be improved if certain definitions are modified to ensure that transactions are not double counted and that orders from larger investors are not wrongly...

SEC Requirements on Adviser Continuity Plans

FSR urges the SEC to take a principles-based approach that requires advisers to plan for possible service disruptions and other (but not all) types of catastrophic events. FSR also notes that advisers should remain in control of the content of their business continuity plan which should remain confidential. The letter notes that the SEC should...

Comment on Proposed FIO Information Collection

In response to an announcement that the Federal Insurance Office (FIO) will collect information for a study on auto insurance pricing, FSR filed a comment letter reiterating its concerns that elements of FIO’s study design are flawed, and that certain issues surrounding FIO’s data security standards should be better clarified.