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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.

The MFA warned that a Federal Reserve Board proposal to restrict the qualified financial contracts of systemically important U.S. banking organizations could "harm the stability of the financial markets while also eroding long-standing and deeply rooted rights of investors, end users and other market participants."

The Managed Funds Association expressed general support for and responded to questions from a European Commission consultation document concerning an effective insolvency framework within the EU.