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Commentary by Steven Lofchie

In response to an Advance Noticed of Proposed Rulemaking that would add "an extra layer of loss-absorbing capacity" in resolving certain large banking organizations, SIFMA said that it is both unnecessary and inappropriate to extend the enhanced resolution requirements to non global systemically important banking organizations whose primary operations are as retail broker-dealers.

Senior officials from the Bank of England, the FDIC, the CFTC, the SEC and the Federal Reserve Board reviewed joint progress on central counterparty resolution issues and on the development of detailed operational planning to support prototype resolution strategies for UK and U.S. CCPs.