Regulatory Comment Letters

Comment Letter to Financial Stability Board on Risk of Asset Management Activities

The Financial Services Roundtable (FSR) urged the Financial Stability Board (FSB) to build any recommendations addressing potential financial stability risks of asset management activities on a foundation of evidence to support such recommendations.  FSR also urged the FSB to gather more information rooted in empirical data and to only recommend...

Proposed Federal Reserve Capital Framework for Insurance Companies

FSR supports the Federal Reserve’s proposal to use state level standards as the basis for a consolidated capital requirement for insurance companies that fall under their jurisdiction. This proposed standard, known as the building-block approach (BBA) would leverage standards that are already in place and could be easily modified to protect...

Joint Industry Letter to the CFPB on Arbitration

FSR, along with 28 other groups, ask the CFPB to withdraw their proposed rulemaking which place limits on arbitration agreements.

Letter to the CFPB on Arbitration

FSR, along with the American Bankers Association and the Consumer Bankers Association note the ways in which a proposed rule from the Consumer Financial Protection Bureau on arbitration fails to protect consumers and is inconsistent with the CFPB’s March 2015 study on consumer arbitration. As result of these deficiencies, the associations urge...

Joint Trade Comments on the Consumer Financial Protection Bureau’s Proposed Arbitration Rule

The American Bankers Association, the Consumer Bankers Association, and the Financial Services Roundtable recently provided comments regarding the Bureau of Consumer Financial Protection’s proposed rule regulating consumer arbitration agreements in financial services contracts published in the Federal Register on May 24, 2016.