A coalition of mortgage lenders and SIFMA made recommendations to the CFPB on proposed revisions to the definition of "Qualified Mortgage" under the Truth in Lending Act.
SIFMA urged the Federal Reserve Board to revise the Global Market Shock and Large Counterparty Default components of the Comprehensive Capital Analysis and Review framework.
The American Banking Association, SIFMA and the Institute of International Bankers proposed revisions to a Federal Reserve Board proposal to modify its regulations for determining "whether a company has the ability to exercise a controlling influence" on another company.
Trade associations urged U.S. regulators to provide guidance on implementing BCBS-IOSCO recommended exemptions from swaps margin requirements where the amounts to be transferred are below relevant thresholds.
In a comment letter, the SIFMA Asset Management Group expressed support for the Financial Stability Oversight Council's proposed "activities-based approach" for addressing systemic risk.
SIFMA recommended a new approach to strengthen cross-border cooperation among regulators to "enhance the coherence of their respective regulations" and "enshrine[] cooperation within legally binding trade agreements."
SIFMA, the Institute of International Bankers, the American Bankers Association and others urged the House Financial Services Committee to amend the "outdated" and "inefficient" Bank Secrecy Act regulatory framework.
ISDA, SIFMA, the American Bankers Association, the Bank Policy Institute and the FIA commented on a proposal by U.S. banking regulators to implement the "standardized approach for counterparty credit risk" in U.S. capital rules.
In a joint comment letter, the Managed Funds Association and SIFMA AMG urged the Basel Committee on Banking Supervision to modify the leverage ratio to align the treatment of cleared derivatives with the standardized approach for measuring counterparty risk in risk-based capital requirements.
Several trade associations requested that the SEC extend the comment period for proposed rules to the capital, margin and segregation requirements for security-based swaps.
A group of financial markets trade associations offered recommendations to regulators to mitigate potential negative impacts as initial margin requirements for uncleared derivatives are expanded to capture buy-side market participants.
SIFMA and the Bank Policy Institute submitted comments to the Federal Reserve Board and the FDIC regarding resolution planning guidance for eight large complex U.S. banking organizations.
SIFMA, ISDA and FIA, among others, submitted comments regarding CFTC-proposed amendments to the de minimis exception within the swap dealer definition of the regulations.
In a new report, ISDA, SIFMA and several other trade associations found that few market participants have implemented programs to begin the transition from interbank offered rates to alternative risk-free rates.
ISDA, the Association of Financial Markets in Europe, International Capital Market Association, and SIFMA highlighted the challenges of transitioning from Interbank Offered Rates to risk free rates.
Several trade associations submitted comment letters responding to the FDIC's proposed rulemaking to restrict the contractual provisions of qualified financial contracts entered into by certain FDIC-supervised institutions.
Industry associations warned the SEC that its proposal on incentive-based compensation arrangements imposes restraints that exceed Dodd-Frank Act rules intended to discourage inappropriate risk-taking at Covered Financial Institutions.
SIFMA filed an amicus curiae brief urging the Second Circuit Court of Appeals not to expand the FDIC Extender Statute beyond the limited scope expressly provided by Congress.
Several financial services associations submitted comments to the Board of Governors of the Federal Reserve System in response to a proposal to impose total loss-absorbing capacity, long-term debt and related "clean holding company" requirements on global systemically important banking groups.
SIFMA provided notice to banking regulators (the Board of Governors of the Federal Reserve, the Office of the Comptroller of the Currency and the FDIC) of a forthcoming change in the treatment of variation margin payments for over-the-counter derivatives by central clearing counterparties ("CCPs"). Historically, variation margin payments have been treated as collateral for outstanding exposure, a treatment that a SIFMA comment letter refers to as the "collateralized to market" ("CTM") model. Going forward, the CCPs will adopt a model by which variation margin payments are treated as settlement of the exposure under the contract, a treatment that the SIFMA comment refers to as the "settled to market" ("STM") model.
The Structured Finance Industry Group, Inc. and SIFMA filed an amicus brief urging the U.S. Supreme Court to grant certiorari and reverse a Second Circuit ruling that the application of state usury laws to third-party assignees is not preempted by the National Bank Act.
